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...
Purchase additions could not be sustained where the taxpayer produced ledgers, invoices, supplier details, registration particulars, bank statements and cheque counterfoils, while undisputed crossed-cheque payments were later realised by third parties. No legal bar then restricted crossed cheques, and the taxpayer could not control their endorsement; absent further inquiry, the High Court restored the first appellate authority's deletion. Wage disallowance based solely on presumed inflation and a doubtful wage register lacked evidentiary support. The High Court set aside the Tribunal's reduced disallowance and restored deletion of both additions; the gross-profit issue remained unanswered.
Purchase additions could not be sustained where the taxpayer produced ledgers, invoices, supplier details, registration particulars, bank statements and cheque counterfoils, while undisputed crossed-cheque payments were later realised by third parties. No legal bar then restricted crossed cheques, and the taxpayer could not control their endorsement; absent further inquiry, the High Court restored the first appellate authority's deletion. Wage disallowance based solely on presumed inflation and a doubtful wage register lacked evidentiary support. The High Court set aside the Tribunal's reduced disallowance and restored deletion of both additions; the gross-profit issue remained unanswered.
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