Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Contemporaneous invoices, GST returns, bank statements and ledger accounts can substantiate labour and manpower expenditure where payments pass through banking channels, tax is deducted at source, and transactions appear in GST records and audited accounts. A vendor's failure to respond to a notice, particularly after being struck off, does not by itself establish that expenditure is unexplained when the supporting evidence remains unrebutted and no further enquiry is undertaken. Purchases included in closing stock and returned in the following year do not affect income where no supplier payment or expenditure claim is made and related GST input is reversed. On these facts, both additions for unexplained expenditure were deleted.
Contemporaneous invoices, GST returns, bank statements and ledger accounts can substantiate labour and manpower expenditure where payments pass through banking channels, tax is deducted at source, and transactions appear in GST records and audited accounts. A vendor's failure to respond to a notice, particularly after being struck off, does not by itself establish that expenditure is unexplained when the supporting evidence remains unrebutted and no further enquiry is undertaken. Purchases included in closing stock and returned in the following year do not affect income where no supplier payment or expenditure claim is made and related GST input is reversed. On these facts, both additions for unexplained expenditure were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
