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...
Compulsory-acquisition compensation under the National Highways Act that remained unpaid on 31 December 2014 and was received in FY 2015-16 qualified for exemption under section 96 of the RFCTLARR Act. The exemption applied notwithstanding the absence of a specific corresponding exemption in the Income-tax Act, resulting in deletion of the long-term capital-gains addition. Interest received for delayed payment of that compensation was separately taxable as income from other sources under binding jurisdictional High Court precedent. The capital-gains addition was deleted, while the addition for delayed-payment interest was sustained.
Compulsory-acquisition compensation under the National Highways Act that remained unpaid on 31 December 2014 and was received in FY 2015-16 qualified for exemption under section 96 of the RFCTLARR Act. The exemption applied notwithstanding the absence of a specific corresponding exemption in the Income-tax Act, resulting in deletion of the long-term capital-gains addition. Interest received for delayed payment of that compensation was separately taxable as income from other sources under binding jurisdictional High Court precedent. The capital-gains addition was deleted, while the addition for delayed-payment interest was sustained.
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