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...
Private-courier delivery of an insolvency demand notice to the corporate debtor's undisputed registered office constitutes effective service where dispatch and delivery establish knowledge and an opportunity to pay or dispute the claim; a technical objection to the service mode does not defeat the proceedings. Foreign-currency advances are converted at the exchange rate on the demand-notice date when testing the operational-debt threshold, while uncrystallised disputed damages may be excluded. Admitted advances for undelivered goods, with no repayment or genuine pre-existing dispute, establish operational debt and default; asserted solvency is not a separate bar. Corporate insolvency resolution proceedings were directed to be initiated, subject to payment before the initiation order.
Private-courier delivery of an insolvency demand notice to the corporate debtor's undisputed registered office constitutes effective service where dispatch and delivery establish knowledge and an opportunity to pay or dispute the claim; a technical objection to the service mode does not defeat the proceedings. Foreign-currency advances are converted at the exchange rate on the demand-notice date when testing the operational-debt threshold, while uncrystallised disputed damages may be excluded. Admitted advances for undelivered goods, with no repayment or genuine pre-existing dispute, establish operational debt and default; asserted solvency is not a separate bar. Corporate insolvency resolution proceedings were directed to be initiated, subject to payment before the initiation order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
