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...
Statutory accumulation of 15 per cent of charitable income under section 11(1)(a) is distinct from further accumulation under section 11(2). Where charitable eligibility and application of income to charitable objects are satisfied, the statutory retention remains available. Accumulation beyond that limit may be claimed where Form No. 10 is furnished by the extended due date for filing the return, rather than only by the original due date. Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late if the audit report was available before return processing and substantive exemption conditions were met.
Statutory accumulation of 15 per cent of charitable income under section 11(1)(a) is distinct from further accumulation under section 11(2). Where charitable eligibility and application of income to charitable objects are satisfied, the statutory retention remains available. Accumulation beyond that limit may be claimed where Form No. 10 is furnished by the extended due date for filing the return, rather than only by the original due date. Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late if the audit report was available before return processing and substantive exemption conditions were met.
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