Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already reflected in arm's length pricing. Cross-examination, corroboration, and a direct link to the relevant year remain necessary for unexplained-money additions.
Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already reflected in arm's length pricing. Cross-examination, corroboration, and a direct link to the relevant year remain necessary for unexplained-money additions.
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