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...
Reducing the subsidy for the purpose of calculation of depreciation - When the statute does not contemplate computation of actual cost of assets after it becomes part of a block of assets, Explanation 10 to Subsection (1) of Section 43 of the Act cannot be made applicable to assets of which the actual cost has been determined and forms part of a block of assets. - AT
Reducing the subsidy for the purpose of calculation of depreciation - When the statute does not contemplate computation of actual cost of assets after it becomes part of a block of assets, Explanation 10 to Subsection (1) of Section 43 of the Act cannot be made applicable to assets of which the actual cost has been determined and forms part of a block of assets. - AT
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