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...
Rule 90(2) limits scrutiny of a GST refund application to its completeness under Rule 89(2), (3) and (4); it does not permit a deficiency memo to decide merits. Objections concerning the correct refund category, required statutory statements, adequacy of foreign-remittance evidence, or limitation require substantive examination by the competent authority. An Advice of Foreign Inward Remittance cannot be rejected solely by its label without assessing whether its contents meet the purpose of a Bank Realisation Certificate or FIRC. Deficiency memos on those grounds were unsustainable, and refiled applications had to be accepted for merits consideration after the applicable opportunity.
Rule 90(2) limits scrutiny of a GST refund application to its completeness under Rule 89(2), (3) and (4); it does not permit a deficiency memo to decide merits. Objections concerning the correct refund category, required statutory statements, adequacy of foreign-remittance evidence, or limitation require substantive examination by the competent authority. An Advice of Foreign Inward Remittance cannot be rejected solely by its label without assessing whether its contents meet the purpose of a Bank Realisation Certificate or FIRC. Deficiency memos on those grounds were unsustainable, and refiled applications had to be accepted for merits consideration after the applicable opportunity.
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