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...
Time-barred DRP objections leave no valid objections for consideration. The AO must complete the assessment under section 144C(4)(b) on the basis of the draft order within the prescribed period and cannot await the DRP's disposal of belated objections. Statutory limitation binds both the assessee and the Revenue. A final assessment issued after that period because of such delay is barred by limitation, void ab initio, and liable to be quashed; merits need not be considered.
Time-barred DRP objections leave no valid objections for consideration. The AO must complete the assessment under section 144C(4)(b) on the basis of the draft order within the prescribed period and cannot await the DRP's disposal of belated objections. Statutory limitation binds both the assessee and the Revenue. A final assessment issued after that period because of such delay is barred by limitation, void ab initio, and liable to be quashed; merits need not be considered.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
