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...
Manufacture - Construction activity at site - ready mix concrete (RMC) - in the entire findings of the Hon’ble Apex Court from para 18 onwards there is no mention of any IS Specification anywhere. In fact Hon’ble Apex Court has not relied at all on the IS Specifications. In these circumstances any changes in the IS Specifications cannot be used to distinguish the decision of Hon’ble Apex Court.
Manufacture - Construction activity at site - ready mix concrete (RMC) - in the entire findings of the Hon’ble Apex Court from para 18 onwards there is no mention of any IS Specification anywhere. In fact Hon’ble Apex Court has not relied at all on the IS Specifications. In these circumstances any changes in the IS Specifications cannot be used to distinguish the decision of Hon’ble Apex Court.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
