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...
EPCG scheme - Failure to fulfill the conditions of the Notification - the appellant had applied for the issuance of the Certificate on November 09, 2016 before the expiry of ten years but it was issued to the appellant by the DGFT only on December 09, 2016. The appellant cannot be blamed for delay of three days since the appellant had admittedly applied for issuance of the certificate on November 09, 2016.- AT
EPCG scheme - Failure to fulfill the conditions of the Notification - the appellant had applied for the issuance of the Certificate on November 09, 2016 before the expiry of ten years but it was issued to the appellant by the DGFT only on December 09, 2016. The appellant cannot be blamed for delay of three days since the appellant had admittedly applied for issuance of the certificate on November 09, 2016.- AT
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