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...
Impleadment of the appellant bank as Proposed 2nd Respondent, in main Company Appeal - necessary/proper party - The Tribunal noted that the bank's interest was protected under pari passu charge and not an exclusive charge. It further highlighted that the bank had previously acquiesced to decisions made without its impleadment, demonstrating that its participation was not crucial for the resolution of the main appeal. - It was determined that the first respondent/appellant was not entitled to possession once the lease expired. The Tribunal rejected the appellant's argument for a right to stay based on investment in the property, citing lack of a valid, enduring lease agreement beyond the explicitly stated term.
Impleadment of the appellant bank as Proposed 2nd Respondent, in main Company Appeal - necessary/proper party - The Tribunal noted that the bank's interest was protected under pari passu charge and not an exclusive charge. It further highlighted that the bank had previously acquiesced to decisions made without its impleadment, demonstrating that its participation was not crucial for the resolution of the main appeal. - It was determined that the first respondent/appellant was not entitled to possession once the lease expired. The Tribunal rejected the appellant's argument for a right to stay based on investment in the property, citing lack of a valid, enduring lease agreement beyond the explicitly stated term.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
