Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
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...
Reopening of assessment - reasons to believe - On the issue of disclosure and compliance with TDS provisions, the court found that the petitioner had indeed disclosed all material facts during the original assessment proceedings. The transactions in question were merely transfers of funds on instructions from the horse owners. - The court held that the objections raised by the petitioner against the reassessment were valid. The authorities had failed to consider the full scope of the disclosures made during the original assessments and erroneously pursued reassessment.
Reopening of assessment - reasons to believe - On the issue of disclosure and compliance with TDS provisions, the court found that the petitioner had indeed disclosed all material facts during the original assessment proceedings. The transactions in question were merely transfers of funds on instructions from the horse owners. - The court held that the objections raised by the petitioner against the reassessment were valid. The authorities had failed to consider the full scope of the disclosures made during the original assessments and erroneously pursued reassessment.
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