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...
Value of the ‘Essar’ brand, trademarks and copyrights purported to have been settled by EIL to the assessee without any consideration, constituted taxable income as per section 56(1) - the CIT(A) had rightly concluded, that as the contribution of brand “Essar” as a gift by EIL to the corpus of the assessee trust did neither involve any profit element which could be brought within the meaning of “Income” under Sec. 2(24) of the Act, nor partook the nature of income, therefore, it could not be subjected to tax under the residuary head i.e “Other sources” u/s 56(1) of the Act, thus, uphold his view to the said extent. - AT
Value of the ‘Essar’ brand, trademarks and copyrights purported to have been settled by EIL to the assessee without any consideration, constituted taxable income as per section 56(1) - the CIT(A) had rightly concluded, that as the contribution of brand “Essar” as a gift by EIL to the corpus of the assessee trust did neither involve any profit element which could be brought within the meaning of “Income” under Sec. 2(24) of the Act, nor partook the nature of income, therefore, it could not be subjected to tax under the residuary head i.e “Other sources” u/s 56(1) of the Act, thus, uphold his view to the said extent. - AT
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TaxTMI 
TaxTMI 
of 4894 
