Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Orders refusing rectification of return-processing adjustments are separately appealable, and limitation for the first appeal runs from service of the rectification order or its intimation, not from an earlier processing intimation. A contingent-liability disclosure does not itself establish a deduction claim. Where tax audit records, financial statements and the processing intimation show that a disputed tax demand was neither charged to profit and loss nor claimed as a deduction, disallowing it increases income for an unclaimed amount and constitutes a mistake apparent from the record. The delay finding was set aside, the appeal was admitted, and the adjustment was directed to be deleted through rectification.
Orders refusing rectification of return-processing adjustments are separately appealable, and limitation for the first appeal runs from service of the rectification order or its intimation, not from an earlier processing intimation. A contingent-liability disclosure does not itself establish a deduction claim. Where tax audit records, financial statements and the processing intimation show that a disputed tax demand was neither charged to profit and loss nor claimed as a deduction, disallowing it increases income for an unclaimed amount and constitutes a mistake apparent from the record. The delay finding was set aside, the appeal was admitted, and the adjustment was directed to be deleted through rectification.
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