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...
Parallel GST adjudication under Sections 73 and 74 for the same financial period was treated as incongruous once adjudication under Section 73 had concluded; the show cause notice, adjudication order and summary order under Section 74 were quashed. The ex parte Section 73 adjudication was also quashed and restored for fresh consideration because the taxpayer asserted that exemption documents and a reply could substantiate its position on the alleged mismatch or erroneous declaration. Reconsideration must occur after receiving the taxpayer's reply and supporting documents, while the merits of the exemption claim remain open.
Parallel GST adjudication under Sections 73 and 74 for the same financial period was treated as incongruous once adjudication under Section 73 had concluded; the show cause notice, adjudication order and summary order under Section 74 were quashed. The ex parte Section 73 adjudication was also quashed and restored for fresh consideration because the taxpayer asserted that exemption documents and a reply could substantiate its position on the alleged mismatch or erroneous declaration. Reconsideration must occur after receiving the taxpayer's reply and supporting documents, while the merits of the exemption claim remain open.
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