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...
The case involved rectification of a mistake u/s 154 for denial of exemption u/s 11. The appellant mistakenly classified income as "business income" instead of "income from other sources," resulting in denial of exemption. The appellant rectified this by submitting a revised return within the prescribed time frame u/s 139(5), not as a Section 154 application. As no intimation u/s 143(1) was issued within the stipulated period, the revised return was deemed accepted. Even if treated as a Section 154 application, the CPC's failure to pass an order within six months led to deemed acceptance. The rejection of a second rectification application lacked justification as all necessary details were provided in the revised return. The tribunal directed the exemption u/s 11 to be granted.
The case involved rectification of a mistake u/s 154 for denial of exemption u/s 11. The appellant mistakenly classified income as "business income" instead of "income from other sources," resulting in denial of exemption. The appellant rectified this by submitting a revised return within the prescribed time frame u/s 139(5), not as a Section 154 application. As no intimation u/s 143(1) was issued within the stipulated period, the revised return was deemed accepted. Even if treated as a Section 154 application, the CPC's failure to pass an order within six months led to deemed acceptance. The rejection of a second rectification application lacked justification as all necessary details were provided in the revised return. The tribunal directed the exemption u/s 11 to be granted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
