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...
Reopening of assessment u/s 147 - reasons are communicated and the reasons would show that the expenditures are expressly disallowed under the deeming fiction created by the penal Section of IT Act, on account of infringement of law. - The assessee can not try to take shelter under the exception provided by the above proviso to Sec.147 that where an assessment order u/s 143 (3) has been completed, no action after the expiry of four years from the end of the assessment year can be taken. - HC
Reopening of assessment u/s 147 - reasons are communicated and the reasons would show that the expenditures are expressly disallowed under the deeming fiction created by the penal Section of IT Act, on account of infringement of law. - The assessee can not try to take shelter under the exception provided by the above proviso to Sec.147 that where an assessment order u/s 143 (3) has been completed, no action after the expiry of four years from the end of the assessment year can be taken. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
