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...
Offence u/s 276CC - petitioner prime facie found that the non-filing of the return was wilfull - Economic Offences - The petitioner's argument that the tax liability was covered by Tax Deducted at Source (TDS) was refuted, as the TDS amount was insufficient. - The High court emphasized the statutory presumption u/s 278E, shifting the burden onto the petitioner to prove absence of wilfulness. - High court dismissed the petitioner's appeal and directed the lower court to proceed with the proceedings, with a timeline for completion.
Offence u/s 276CC - petitioner prime facie found that the non-filing of the return was wilfull - Economic Offences - The petitioner's argument that the tax liability was covered by Tax Deducted at Source (TDS) was refuted, as the TDS amount was insufficient. - The High court emphasized the statutory presumption u/s 278E, shifting the burden onto the petitioner to prove absence of wilfulness. - High court dismissed the petitioner's appeal and directed the lower court to proceed with the proceedings, with a timeline for completion.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
