Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
GST deregistration, subsequent non-filing of returns, a supplier's absence from its address, or vehicle discrepancies do not alone establish that documented purchases are bogus. Purchase orders, subcontract agreements, invoices, delivery records, e-way bills, GST records, attendance and project records, and banking payments support the genuineness of materials, labour, housekeeping and manpower transactions, particularly where books remain unrejected and contracts are undisputed. Incomplete third-party statements or chat extracts not supplied to the taxpayer, and not linked to its transactions, lack evidentiary force. Revenue must establish a nexus between alleged supplier fund diversion and taxpayer transactions; a taxpayer denying a transaction cannot be required to prove a negative.
GST deregistration, subsequent non-filing of returns, a supplier's absence from its address, or vehicle discrepancies do not alone establish that documented purchases are bogus. Purchase orders, subcontract agreements, invoices, delivery records, e-way bills, GST records, attendance and project records, and banking payments support the genuineness of materials, labour, housekeeping and manpower transactions, particularly where books remain unrejected and contracts are undisputed. Incomplete third-party statements or chat extracts not supplied to the taxpayer, and not linked to its transactions, lack evidentiary force. Revenue must establish a nexus between alleged supplier fund diversion and taxpayer transactions; a taxpayer denying a transaction cannot be required to prove a negative.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
