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...
Benami characterisation of land acquired in an apparent purchaser's name rested on cumulative evidence of limited financial means, a statement that the sale deed was signed at the beneficial owner's behest, documented nexus between them, and proof of the payment source. A later retraction affidavit lacked support and was treated as unreliable because it conflicted with the sale deed, was delayed without explanation, and referred to an implausible future event. The land was treated as benami property, sustaining confirmation of provisional attachment.
Benami characterisation of land acquired in an apparent purchaser's name rested on cumulative evidence of limited financial means, a statement that the sale deed was signed at the beneficial owner's behest, documented nexus between them, and proof of the payment source. A later retraction affidavit lacked support and was treated as unreliable because it conflicted with the sale deed, was delayed without explanation, and referred to an implausible future event. The land was treated as benami property, sustaining confirmation of provisional attachment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
