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...
Seeking review - error apparent on the face of record or not - The High Court held that, these documents were not part of the pleadings. Review does not mean rehearing or appeal. - The Court concluded that there was no error apparent on the face of the record in the original judgment, thus finding no grounds to entertain the review petitions. Consequently, the review petitions were dismissed, upholding the initial ruling that granted specific tax relief to FL3 licensees for the lockdown periods without extending the same considerations to earlier fiscal years.
Seeking review - error apparent on the face of record or not - The High Court held that, these documents were not part of the pleadings. Review does not mean rehearing or appeal. - The Court concluded that there was no error apparent on the face of the record in the original judgment, thus finding no grounds to entertain the review petitions. Consequently, the review petitions were dismissed, upholding the initial ruling that granted specific tax relief to FL3 licensees for the lockdown periods without extending the same considerations to earlier fiscal years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
