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...
Service of reassessment notices under section 148A(b) must provide the petitioner a genuine opportunity to respond. Where notices and the section 148A(d) order were sent to a secondary email address and a former residential address, a further response opportunity was warranted. The reassessment notice and order, assessment, consequential demands, penalty orders and recovery notice were quashed, while reassessment proceedings were restored and the petitioner was permitted to respond within the stipulated time. Merits remained open.
Service of reassessment notices under section 148A(b) must provide the petitioner a genuine opportunity to respond. Where notices and the section 148A(d) order were sent to a secondary email address and a former residential address, a further response opportunity was warranted. The reassessment notice and order, assessment, consequential demands, penalty orders and recovery notice were quashed, while reassessment proceedings were restored and the petitioner was permitted to respond within the stipulated time. Merits remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
