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...
Business-expenditure deductibility after transfer of a branch undertaking depends on whether retained statutory assets and related expenditure continued to serve the business. The phrase "for the purpose of business" extends to acts incidental to carrying on business, but substantial legal and professional expenses cannot be allowed without complete particulars on their nature, purpose, and connection with business operations. Where those facts have not been examined, the disallowance requires fresh factual verification. The expenditure claim was remitted for de novo assessment, with the disallowance set aside for reconsideration in accordance with law.
Business-expenditure deductibility after transfer of a branch undertaking depends on whether retained statutory assets and related expenditure continued to serve the business. The phrase "for the purpose of business" extends to acts incidental to carrying on business, but substantial legal and professional expenses cannot be allowed without complete particulars on their nature, purpose, and connection with business operations. Where those facts have not been examined, the disallowance requires fresh factual verification. The expenditure claim was remitted for de novo assessment, with the disallowance set aside for reconsideration in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
