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...
TDS u/s 195 - compensation paid for breach of contract for supply of material to foreign buyer - assessee’s failure to supply the export order which constitutes business transaction - There is no evidence brought on record that the sum paid to foreign buyer is income within the meaning of Article VII of DTAA to be taxable in India - neither TDS required nor disallowance u/s 40(a)(i)
TDS u/s 195 - compensation paid for breach of contract for supply of material to foreign buyer - assessee’s failure to supply the export order which constitutes business transaction - There is no evidence brought on record that the sum paid to foreign buyer is income within the meaning of Article VII of DTAA to be taxable in India - neither TDS required nor disallowance u/s 40(a)(i)
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
