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...
Condonation of delay in filing appeal before the Commissioner (Appeals) - Dismissal of appeal on the ground that the appeal was delayed by thirty three days - exclusion of the period during which the matter was pending before the High Court. - The Supreme court found merit in the appellant's argument and held that the delay in filing the appeal should be condoned under the proviso to sub-section 3A of Section 85 of the Finance Act, 1994. Consequently, the impugned orders were set aside, and the matter was restored to the file of the Commissioner (Appeals)
Condonation of delay in filing appeal before the Commissioner (Appeals) - Dismissal of appeal on the ground that the appeal was delayed by thirty three days - exclusion of the period during which the matter was pending before the High Court. - The Supreme court found merit in the appellant's argument and held that the delay in filing the appeal should be condoned under the proviso to sub-section 3A of Section 85 of the Finance Act, 1994. Consequently, the impugned orders were set aside, and the matter was restored to the file of the Commissioner (Appeals)
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