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...
Bogus purchases - profit estimation on alleged party @ 12.50% - no material to substantiate the view taken by the AO - comparing the GP rate on other purchases and overall G.P rate declared, it was held that assessee is operating on low margin, hence the rate of G.P should be at rate earned from other purchases
Bogus purchases - profit estimation on alleged party @ 12.50% - no material to substantiate the view taken by the AO - comparing the GP rate on other purchases and overall G.P rate declared, it was held that assessee is operating on low margin, hence the rate of G.P should be at rate earned from other purchases
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