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...
SVLDRS - The court acknowledged that the petitioner failed to make the balance payment within the extended period due to financial constraints post-COVID-19. However, it emphasized that the petitioner did not provide substantial evidence of severe financial crunch, as claimed. - Citing a precedent set by the Supreme Court, the court affirmed that the time limit cannot be extended by the court as it would amount to modifying the scheme, a prerogative of the government or the respondent authority. The extension granted during the COVID-19 pandemic was within the authority of the government, not the court.
SVLDRS - The court acknowledged that the petitioner failed to make the balance payment within the extended period due to financial constraints post-COVID-19. However, it emphasized that the petitioner did not provide substantial evidence of severe financial crunch, as claimed. - Citing a precedent set by the Supreme Court, the court affirmed that the time limit cannot be extended by the court as it would amount to modifying the scheme, a prerogative of the government or the respondent authority. The extension granted during the COVID-19 pandemic was within the authority of the government, not the court.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
