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...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Closing-stock valuation based on net realisable value requires supporting material establishing the basis of that value. The High Court found that the assessee had not substantiated its claimed net realisable value, while the Assessing Officer adopted a realisable or market value below cost. The principle of consistency did not apply because there was no change in the valuation method. The appellate authorities' findings on the applicable valuation rate were concurrent findings of fact, raising no substantial question of law. The addition for undervaluation of closing stock was therefore sustained and the tax appeal was dismissed.
Closing-stock valuation based on net realisable value requires supporting material establishing the basis of that value. The High Court found that the assessee had not substantiated its claimed net realisable value, while the Assessing Officer adopted a realisable or market value below cost. The principle of consistency did not apply because there was no change in the valuation method. The appellate authorities' findings on the applicable valuation rate were concurrent findings of fact, raising no substantial question of law. The addition for undervaluation of closing stock was therefore sustained and the tax appeal was dismissed.
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