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...
Revision u/s 263 - It is evident that A.O. made enquiries on the issue and assessee complied to the enquiries and filed all the required details. Thus, it is not a case where that A.O. made no enquiry or verification which should have been made. It is clear from reading of notice u/s 263 of the Act, that the proceedings u/s 263 has been started on the same issue which have already been considered and examined by the then A.O. - Revision order set aside - AT
Revision u/s 263 - It is evident that A.O. made enquiries on the issue and assessee complied to the enquiries and filed all the required details. Thus, it is not a case where that A.O. made no enquiry or verification which should have been made. It is clear from reading of notice u/s 263 of the Act, that the proceedings u/s 263 has been started on the same issue which have already been considered and examined by the then A.O. - Revision order set aside - AT
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