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...
Section 119(2)(b) permits exceptional admission of a delayed exemption, deduction or refund claim after the revised-return period under Section 139(5) has expired, where this is necessary to avoid genuine hardship. Condonation removes only the procedural bar; exemption, taxability, refund and interest remain subject to independent merits determination under the applicable provisions. Genuine hardship requires a fact-sensitive assessment of bona fides, promptness, the nature of the omission and the practical consequence of refusal. Prima facie verification may test whether the claim is genuine and supportable, but must not become a final adjudication. Comparable decisions may establish that a claim is arguable, while factual verification and substantive scrutiny remain available after admission.
Section 119(2)(b) permits exceptional admission of a delayed exemption, deduction or refund claim after the revised-return period under Section 139(5) has expired, where this is necessary to avoid genuine hardship. Condonation removes only the procedural bar; exemption, taxability, refund and interest remain subject to independent merits determination under the applicable provisions. Genuine hardship requires a fact-sensitive assessment of bona fides, promptness, the nature of the omission and the practical consequence of refusal. Prima facie verification may test whether the claim is genuine and supportable, but must not become a final adjudication. Comparable decisions may establish that a claim is arguable, while factual verification and substantive scrutiny remain available after admission.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
