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...
CENVAT Credit - Levy of interest and penalty - the appellant after receipt of orders from the department relating to erroneous credit taken by them as per Rule 6 of CCR 2004, cannot continue to plead ambiguity in the interpretation of the said provision and claim that having reversed wrongly taken credits, that too as per their interpretation of the Rule, the imposition of interest and penalty is unsustainable. - AT
CENVAT Credit - Levy of interest and penalty - the appellant after receipt of orders from the department relating to erroneous credit taken by them as per Rule 6 of CCR 2004, cannot continue to plead ambiguity in the interpretation of the said provision and claim that having reversed wrongly taken credits, that too as per their interpretation of the Rule, the imposition of interest and penalty is unsustainable. - AT
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