Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
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...
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Transaction-specific investigation information identifying the taxpayer, supplier and disputed transaction can support reassessment under the substituted regime after pre-notice procedure; its Investigation Wing origin alone does not make it vague. A retrospective clarification permits a Jurisdictional Assessing Officer to issue the reassessment notice. Where corresponding sales, purchase records and banking evidence exist but the named supplier is untraceable and does not comply, purchases cannot be wholly disallowed; absent evidence that payments returned in cash, addition is limited to the embedded profit. The disputed-purchase addition was restricted to 6%. A monetary-limit exception for departmental appeals affects maintainability but does not itself require vacating the appellate order or remanding assessment.
Transaction-specific investigation information identifying the taxpayer, supplier and disputed transaction can support reassessment under the substituted regime after pre-notice procedure; its Investigation Wing origin alone does not make it vague. A retrospective clarification permits a Jurisdictional Assessing Officer to issue the reassessment notice. Where corresponding sales, purchase records and banking evidence exist but the named supplier is untraceable and does not comply, purchases cannot be wholly disallowed; absent evidence that payments returned in cash, addition is limited to the embedded profit. The disputed-purchase addition was restricted to 6%. A monetary-limit exception for departmental appeals affects maintainability but does not itself require vacating the appellate order or remanding assessment.
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