Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.
Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
