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...
Extended period of limitation - Recovery of service tax - service being taxable but the liability has not been discharged by the appellant - the Department has wrongly invoked the extended period of limitation. - nothing of this sort is apparent on part of the appellant - Department has wrongly invoked the extended period of limitation. Both the SCNs are therefore, held to be barred by the period of limitation. - AT
Extended period of limitation - Recovery of service tax - service being taxable but the liability has not been discharged by the appellant - the Department has wrongly invoked the extended period of limitation. - nothing of this sort is apparent on part of the appellant - Department has wrongly invoked the extended period of limitation. Both the SCNs are therefore, held to be barred by the period of limitation. - AT
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