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...
Related-party commission expenditure under section 40A(2)(b) is not disallowable solely because payment is made to a related person. Excessiveness or unreasonableness must be assessed against the fair market value of services, legitimate business needs, and benefit derived. A benchmark from an unrelated line of business, unsupported by comparable material, cannot establish that commission is excessive. Verification remains necessary to confirm services rendered and their commercial justification. Applying these principles, the related-party commission disallowance was deleted.
Related-party commission expenditure under section 40A(2)(b) is not disallowable solely because payment is made to a related person. Excessiveness or unreasonableness must be assessed against the fair market value of services, legitimate business needs, and benefit derived. A benchmark from an unrelated line of business, unsupported by comparable material, cannot establish that commission is excessive. Verification remains necessary to confirm services rendered and their commercial justification. Applying these principles, the related-party commission disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
