Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.
Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
