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...
Return transit of duty-paid imported goods to a bonded warehouse after an aborted delivery, supported by import and customs-clearance documents and showing no quantity discrepancy, is treated as a logistical fallback rather than an unrecorded commercial movement. Section 129 detention and confiscatory penalty should not apply to a fresh e-way bill omission where the transaction is accounted for, duty has been paid, and no intent to evade tax or revenue loss exists. Such bona fide transit-documentation defaults attract only the general penalty under Section 125; the Section 129 penalty and related orders were set aside.
Return transit of duty-paid imported goods to a bonded warehouse after an aborted delivery, supported by import and customs-clearance documents and showing no quantity discrepancy, is treated as a logistical fallback rather than an unrecorded commercial movement. Section 129 detention and confiscatory penalty should not apply to a fresh e-way bill omission where the transaction is accounted for, duty has been paid, and no intent to evade tax or revenue loss exists. Such bona fide transit-documentation defaults attract only the general penalty under Section 125; the Section 129 penalty and related orders were set aside.
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