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...
Disallowance u/s 14A r.w.r. 8D - in the case of mutual funds, administrative and managerial expenses are factored in the investments itself - the explanation offered by the assessee for non applicability of rule 8D(2)(iii) for rigid disallowance appears to be in congruity with market practice - not a fit case for resorting to double disallowance of similar expenditure
Disallowance u/s 14A r.w.r. 8D - in the case of mutual funds, administrative and managerial expenses are factored in the investments itself - the explanation offered by the assessee for non applicability of rule 8D(2)(iii) for rigid disallowance appears to be in congruity with market practice - not a fit case for resorting to double disallowance of similar expenditure
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
