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...
Builder-financing additions for alleged cash receipts or payments cannot be sustained as unexplained money or unexplained investment where the amount represents return of an accounted banking-channel advance and no independent unexplained source or accretion is established. Alleged interest income cannot be inferred solely from a purported financing arrangement where property acquisitions were explained as investments generating rental income and capital gains. Stamp-duty valuation provisions apply to immovable-property acquisitions irrespective of their characterisation as builder financing. Where the stamp-duty value of under-construction property is disputed, fair market value must be determined through the statutory valuation mechanism before taxability and quantum are decided; the valuation issues require DVO-based fresh determination after hearing the assessee.
Builder-financing additions for alleged cash receipts or payments cannot be sustained as unexplained money or unexplained investment where the amount represents return of an accounted banking-channel advance and no independent unexplained source or accretion is established. Alleged interest income cannot be inferred solely from a purported financing arrangement where property acquisitions were explained as investments generating rental income and capital gains. Stamp-duty valuation provisions apply to immovable-property acquisitions irrespective of their characterisation as builder financing. Where the stamp-duty value of under-construction property is disputed, fair market value must be determined through the statutory valuation mechanism before taxability and quantum are decided; the valuation issues require DVO-based fresh determination after hearing the assessee.
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