Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
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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TaxTMI 
TaxTMI 
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