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...
Foreign LTC/LFC payments involving an overseas leg or circuitous route fall outside the Section 10(5) exemption, which Rule 2B limits to actual eligible travel to a place in India and shortest-route fare ceilings. Reimbursement limited to a domestic-fare equivalent or a domestic segment does not preserve the exemption. Under Section 192, employers must include known non-exempt payments in estimated salary and deduct tax based on available claim particulars, although they have no unlimited verification duty. Interim recovery restraints do not automatically suspend TDS obligations. Section 201 relief requires recipient-specific return, tax-payment and accountant-certificate proof; interest and Section 271C penalty require separate analysis, including reasonable cause.
Foreign LTC/LFC payments involving an overseas leg or circuitous route fall outside the Section 10(5) exemption, which Rule 2B limits to actual eligible travel to a place in India and shortest-route fare ceilings. Reimbursement limited to a domestic-fare equivalent or a domestic segment does not preserve the exemption. Under Section 192, employers must include known non-exempt payments in estimated salary and deduct tax based on available claim particulars, although they have no unlimited verification duty. Interim recovery restraints do not automatically suspend TDS obligations. Section 201 relief requires recipient-specific return, tax-payment and accountant-certificate proof; interest and Section 271C penalty require separate analysis, including reasonable cause.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
