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...
Uncorroborated third-party search material cannot support additions for alleged cash coal purchases where recorded sales, coal consumption, production and books remain accepted, and no abnormal input-output pattern or independent evidence is established. Estimated profit from hypothetical unrecorded coal sales was therefore deleted. Likewise, a retracted statement alleging under-invoicing of mill scale sales, coupled with CCTV-based presumptions, is insufficient where the cash is explained as recorded and no independent evidence confirms suppressed sales. The estimated-profit additions for alleged mill scale suppression were deleted for both assessment years, and the appeals succeeded.
Uncorroborated third-party search material cannot support additions for alleged cash coal purchases where recorded sales, coal consumption, production and books remain accepted, and no abnormal input-output pattern or independent evidence is established. Estimated profit from hypothetical unrecorded coal sales was therefore deleted. Likewise, a retracted statement alleging under-invoicing of mill scale sales, coupled with CCTV-based presumptions, is insufficient where the cash is explained as recorded and no independent evidence confirms suppressed sales. The estimated-profit additions for alleged mill scale suppression were deleted for both assessment years, and the appeals succeeded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
