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...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
100% EOU - served from India scheme (SFIS) - Recovery of duties of customs foregone - There is no finding in the order of the original authority holding the goods liable to confiscation; the imposition of penalty under section 112 of Customs Act, 1962 is without authority of law. Neither is there any finding on the confiscability of goods under rule 25 of Central Excise Act, 1944 and the imposition of penalty thereunder is, therefore, without authority of law. - AT
100% EOU - served from India scheme (SFIS) - Recovery of duties of customs foregone - There is no finding in the order of the original authority holding the goods liable to confiscation; the imposition of penalty under section 112 of Customs Act, 1962 is without authority of law. Neither is there any finding on the confiscability of goods under rule 25 of Central Excise Act, 1944 and the imposition of penalty thereunder is, therefore, without authority of law. - AT
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