Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
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...
Validity of remand of matter to the AA to pass fresh order - It is settled principles of law that every decision is to be supported by reasons inasmuch as reasoning is the heart beat of every judgment. Without assigning any reasons as to how the order of the FAA is wrong, setting aside the order of the FAA and remanding the matter to AA by the Karnataka Appellate Tribunal, in our considered opinion has thus resulted in miscarriage of justice and error of jurisdiction which would entitle the Revision Petitioner to seek interference at the hands of this court. - HC
Validity of remand of matter to the AA to pass fresh order - It is settled principles of law that every decision is to be supported by reasons inasmuch as reasoning is the heart beat of every judgment. Without assigning any reasons as to how the order of the FAA is wrong, setting aside the order of the FAA and remanding the matter to AA by the Karnataka Appellate Tribunal, in our considered opinion has thus resulted in miscarriage of justice and error of jurisdiction which would entitle the Revision Petitioner to seek interference at the hands of this court. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
