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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
