Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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...
TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses while working out net profit margin of “Domestic-Personal care division”. - it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses while working out net profit margin of “Domestic-Personal care division”. - it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
