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...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
For a vegetable-market commission agent claiming status as a kachha arhtia, sale proceeds handled for principals do not constitute turnover for tax-audit purposes; gross commission alone is relevant under the CBDT Circular. Status must be verified because no conclusive material ruled out own-account purchases or sales. The penalty issue was restored for limited verification: proof of exclusive agency eliminates the audit obligation and penalty; otherwise, the penalty's sustainability must be determined in accordance with law.
For a vegetable-market commission agent claiming status as a kachha arhtia, sale proceeds handled for principals do not constitute turnover for tax-audit purposes; gross commission alone is relevant under the CBDT Circular. Status must be verified because no conclusive material ruled out own-account purchases or sales. The penalty issue was restored for limited verification: proof of exclusive agency eliminates the audit obligation and penalty; otherwise, the penalty's sustainability must be determined in accordance with law.
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