Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
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