Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
