Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Advance-tax payment otherwise payable is a precondition to admission of an income-tax appeal where no return of income has been filed, unless exemption is sought and granted for good and sufficient reason. A claimed absence of taxable income and corresponding advance-tax liability requires examination where neither the taxpayer nor the Assessing Officer has computed the liability; it cannot be rejected summarily merely because no exemption application was filed. Dismissal for non-compliance in those circumstances requires fresh consideration with an opportunity to explain the claim. Penalty appeals concerning under-reporting of income and audit default, where based on the same admission objection, follow the same treatment.
Advance-tax payment otherwise payable is a precondition to admission of an income-tax appeal where no return of income has been filed, unless exemption is sought and granted for good and sufficient reason. A claimed absence of taxable income and corresponding advance-tax liability requires examination where neither the taxpayer nor the Assessing Officer has computed the liability; it cannot be rejected summarily merely because no exemption application was filed. Dismissal for non-compliance in those circumstances requires fresh consideration with an opportunity to explain the claim. Penalty appeals concerning under-reporting of income and audit default, where based on the same admission objection, follow the same treatment.
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