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...
Revision u/s 263 - period of limitation - the case was re-assessed u/s. 143(3) r.w.s. 147 - the case of the assessee was again reopened and the assessment u/s. 143(3) r.w.s. 147 of the Act was completed 22.12.2017. No doubt, original assessment order is liable to be considered to reckon the limitation and accordingly passing the order on 21.03.2021 u/s. 263(2) of the Act is clearly barred by limitation which is beyond two years. - AT
Revision u/s 263 - period of limitation - the case was re-assessed u/s. 143(3) r.w.s. 147 - the case of the assessee was again reopened and the assessment u/s. 143(3) r.w.s. 147 of the Act was completed 22.12.2017. No doubt, original assessment order is liable to be considered to reckon the limitation and accordingly passing the order on 21.03.2021 u/s. 263(2) of the Act is clearly barred by limitation which is beyond two years. - AT
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