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...
Classification of imported stainless-steel melting scrap requires consignment-specific, reliable evidence; test reports for later consignments cannot displace a separately finalised assessment. Pre-shipment inspection and Chartered Engineer reports identifying goods as scrap remain material where chemical or laboratory evidence is inadequate, and buyer statements not tested under the prescribed evidentiary procedure cannot establish prime material. Uniform dimensions or orderly stacking do not alone establish prime material, while revaluation requires support for additional consideration. Goods cleared without bond or undertaking and unavailable for confiscation cannot be absolutely confiscated. Director penalties require a specific basis for personal responsibility. All consignments were treated as scrap, with enhanced values, confiscation and penalties set aside; demurrage waiver was directed for detained goods.
Classification of imported stainless-steel melting scrap requires consignment-specific, reliable evidence; test reports for later consignments cannot displace a separately finalised assessment. Pre-shipment inspection and Chartered Engineer reports identifying goods as scrap remain material where chemical or laboratory evidence is inadequate, and buyer statements not tested under the prescribed evidentiary procedure cannot establish prime material. Uniform dimensions or orderly stacking do not alone establish prime material, while revaluation requires support for additional consideration. Goods cleared without bond or undertaking and unavailable for confiscation cannot be absolutely confiscated. Director penalties require a specific basis for personal responsibility. All consignments were treated as scrap, with enhanced values, confiscation and penalties set aside; demurrage waiver was directed for detained goods.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
