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...
Incorrect selection of an applicable clause or code in Form 10AB for charitable registration or approval, when bona fide and inadvertent, warrants an opportunity for rectification rather than rejection solely on that technical ground. Where provisional registration has been granted on the same application, the technical error should not prevent consideration on merits. Applications may be reconsidered after correction of the form and a proper hearing, ensuring that procedural defects do not defeat substantive eligibility.
Incorrect selection of an applicable clause or code in Form 10AB for charitable registration or approval, when bona fide and inadvertent, warrants an opportunity for rectification rather than rejection solely on that technical ground. Where provisional registration has been granted on the same application, the technical error should not prevent consideration on merits. Applications may be reconsidered after correction of the form and a proper hearing, ensuring that procedural defects do not defeat substantive eligibility.
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