Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Third-party seized diaries and excel sheets cannot support additions for alleged cash rebate repayment or unaccounted molasses sales unless they clearly establish the transactions and are supported by independent corroborative evidence. Unsigned, ambiguous entries, a retracted statement, and denial of cross-examination undermine their evidentiary value and breach natural justice; the related additions were deleted. Disallowance computed under section 14A read with Rule 8D cannot be imported into book-profit computation under section 115JB, requiring deletion of that adjustment. Components integral to a cogeneration plant, without standalone function, qualify for the higher depreciation rate applicable to the plant; the depreciation disallowance was deleted.
Third-party seized diaries and excel sheets cannot support additions for alleged cash rebate repayment or unaccounted molasses sales unless they clearly establish the transactions and are supported by independent corroborative evidence. Unsigned, ambiguous entries, a retracted statement, and denial of cross-examination undermine their evidentiary value and breach natural justice; the related additions were deleted. Disallowance computed under section 14A read with Rule 8D cannot be imported into book-profit computation under section 115JB, requiring deletion of that adjustment. Components integral to a cogeneration plant, without standalone function, qualify for the higher depreciation rate applicable to the plant; the depreciation disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4896 
