Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Reopening of assessment - reasons for re-opening within or beyond 4 years - reasons to believe - The court specifically pointed out that the information used from the DRI and the Shah Commission reports was not adequately scrutinized independently by the assessing officers to form a reasonable belief of tax evasion. The court noted that the decision of the Supreme Court, which found mining leases post-2007 to be illegal, could not retroactively make previous business activities illegal for tax purposes. The court emphasized that such interpretations were not known or could not have been known by the taxpayers at the time of filing their returns.
Reopening of assessment - reasons for re-opening within or beyond 4 years - reasons to believe - The court specifically pointed out that the information used from the DRI and the Shah Commission reports was not adequately scrutinized independently by the assessing officers to form a reasonable belief of tax evasion. The court noted that the decision of the Supreme Court, which found mining leases post-2007 to be illegal, could not retroactively make previous business activities illegal for tax purposes. The court emphasized that such interpretations were not known or could not have been known by the taxpayers at the time of filing their returns.
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