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...
An uncancelled duty-free import licence obtained through fraud or misrepresentation remains voidable rather than void from inception. Where the licence was genuinely issued, endorsed transferable and not cancelled by the competent authority, a bona fide transferee for value without notice of third-party fraud in export-obligation certification is distinct from the fraudster and cannot be subjected to duty, interest or redemption fine for imports under that licence. The principle that fraud vitiates everything does not displace those rights in this setting. A statutory appeal confined to substantial questions framed at admission cannot be decided on an unframed limitation ground unless an additional question is formally permitted. The duty demand, interest and redemption fine were quashed.
An uncancelled duty-free import licence obtained through fraud or misrepresentation remains voidable rather than void from inception. Where the licence was genuinely issued, endorsed transferable and not cancelled by the competent authority, a bona fide transferee for value without notice of third-party fraud in export-obligation certification is distinct from the fraudster and cannot be subjected to duty, interest or redemption fine for imports under that licence. The principle that fraud vitiates everything does not displace those rights in this setting. A statutory appeal confined to substantial questions framed at admission cannot be decided on an unframed limitation ground unless an additional question is formally permitted. The duty demand, interest and redemption fine were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
