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...
Addition made u/s. 69/69B - difference between the stamp duty value and the sale consideration with respect to purchase of property - family settlement to constitute "transfer" or not - The Tribunal found that the addition under section 69 was incorrect as the investment was recorded in the books. For section 69B, the AO failed to provide evidence that the assessee expended more than recorded. The Tribunal also noted that section 56(2)(vii)(b) was not applicable to companies and section 56(2)(x) was effective from AY 2017-18. The Tribunal concluded that the transaction under family settlement did not amount to a "transfer" and deleted the addition.
Addition made u/s. 69/69B - difference between the stamp duty value and the sale consideration with respect to purchase of property - family settlement to constitute "transfer" or not - The Tribunal found that the addition under section 69 was incorrect as the investment was recorded in the books. For section 69B, the AO failed to provide evidence that the assessee expended more than recorded. The Tribunal also noted that section 56(2)(vii)(b) was not applicable to companies and section 56(2)(x) was effective from AY 2017-18. The Tribunal concluded that the transaction under family settlement did not amount to a "transfer" and deleted the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
