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...
Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.
Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
