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...
Reassessment initiated on specific Investigation Wing information about substantial cash deposits was sustained where the Assessing Officer examined the information and formed a belief that income had escaped assessment. Recording cash receipts as sales did not by itself establish that corresponding bank deposits arose from business sales; reliable linkage among the sales, stock movement and deposits was required to rebut an unexplained cash-credit addition. A challenge to mere initiation of penalty proceedings was premature, while interest levied consequentially on the assessment followed the assessment outcome.
Reassessment initiated on specific Investigation Wing information about substantial cash deposits was sustained where the Assessing Officer examined the information and formed a belief that income had escaped assessment. Recording cash receipts as sales did not by itself establish that corresponding bank deposits arose from business sales; reliable linkage among the sales, stock movement and deposits was required to rebut an unexplained cash-credit addition. A challenge to mere initiation of penalty proceedings was premature, while interest levied consequentially on the assessment followed the assessment outcome.
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