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...
Common expenditure proportionately allocated to taxable non-member receipts of a mutual concern is deductible where the expenses are genuine, relate to earning those receipts, and the allocation method has been consistently followed; an estimated restriction without disclosed basis or cogent material cannot stand. The disallowance was deleted. Rent from terrace space leased to a cellular operator for a tower was treated as income from house property, attracting statutory deductions rather than income from other sources. The appeal succeeded on those issues. The challenge to the scrutiny notice for alleged non-compliance with CBDT instructions was dismissed because a cited Special Bench ruling covered the issue against the assessee.
Common expenditure proportionately allocated to taxable non-member receipts of a mutual concern is deductible where the expenses are genuine, relate to earning those receipts, and the allocation method has been consistently followed; an estimated restriction without disclosed basis or cogent material cannot stand. The disallowance was deleted. Rent from terrace space leased to a cellular operator for a tower was treated as income from house property, attracting statutory deductions rather than income from other sources. The appeal succeeded on those issues. The challenge to the scrutiny notice for alleged non-compliance with CBDT instructions was dismissed because a cited Special Bench ruling covered the issue against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
