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...
Statutory appellate jurisdiction does not permit the First Appellate Authority to condone delay beyond the enactment's prescribed outer limit; equitable relief available in writ jurisdiction cannot enlarge that power. Condonation beyond that limit renders consequential appellate orders legally unsustainable. Where the Department has implemented those orders by restoring cancelled registrations, altering the registrants' legal and commercial position and permitting business continuation, it cannot seek annulment without addressing the consequences of restoration. The absence of effective, workable relief makes the Department's challenge infructuous and not maintainable.
Statutory appellate jurisdiction does not permit the First Appellate Authority to condone delay beyond the enactment's prescribed outer limit; equitable relief available in writ jurisdiction cannot enlarge that power. Condonation beyond that limit renders consequential appellate orders legally unsustainable. Where the Department has implemented those orders by restoring cancelled registrations, altering the registrants' legal and commercial position and permitting business continuation, it cannot seek annulment without addressing the consequences of restoration. The absence of effective, workable relief makes the Department's challenge infructuous and not maintainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
