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...
Penalty u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
Penalty u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
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