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 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the assessee to tell as to how the Assessing Officer has to complete the assessment. - It would be a clear case of change of opinion. What the Assessing Officer purported to do is to review his earlier decision. - proceedings of reopening quashed - HC
Reopening of assessment u/s 147 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the assessee to tell as to how the Assessing Officer has to complete the assessment. - It would be a clear case of change of opinion. What the Assessing Officer purported to do is to review his earlier decision. - proceedings of reopening quashed - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
