Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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...
Consequential assessment following revision directions was confined to verifying DCF share valuation and projection assumptions; because the directions did not require treating share premium as unexplained cash credit, the Section 68 addition was deleted. Where valuation exceeded fair market value, Section 56(2)(viib), subject to its conditions, was identified as the relevant provision. For AY 2014-15, the unamended Section 68 required proof of creditor identity, transaction genuineness and lender creditworthiness, not source of source. Generalised treatment of lender evidence required limited lender-wise verification, so the unsecured-loan addition was remanded without a merits determination.
Consequential assessment following revision directions was confined to verifying DCF share valuation and projection assumptions; because the directions did not require treating share premium as unexplained cash credit, the Section 68 addition was deleted. Where valuation exceeded fair market value, Section 56(2)(viib), subject to its conditions, was identified as the relevant provision. For AY 2014-15, the unamended Section 68 required proof of creditor identity, transaction genuineness and lender creditworthiness, not source of source. Generalised treatment of lender evidence required limited lender-wise verification, so the unsecured-loan addition was remanded without a merits determination.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
