Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Addition based on unsubstantiated documents like loose sheets, jottings, and Excel sheets - unaccounted cash receipts from students - cannot be sustained. Statements recorded solely cannot constitute incriminating material for additions. Unsubstantiated loose papers without corroboration by inquiry or leading to undisclosed assets cannot be basis for additions. Suspicion alone cannot replace evidence. AO failed to establish live link between seized material and unaccounted fees resulting in undisclosed assets. Uncorroborated seized material alone cannot be considered conclusive evidence. Presumption u/s 132(4) is rebuttable. AO should act judicially on adequate material, not arbitrarily. Additions cannot be made without examining concerned students/parents. Mere notes in diaries/loose sheets require corroboration. Non-speaking documents without corroborative evidence showing undisclosed income cannot be relied upon for additions.
Addition based on unsubstantiated documents like loose sheets, jottings, and Excel sheets - unaccounted cash receipts from students - cannot be sustained. Statements recorded solely cannot constitute incriminating material for additions. Unsubstantiated loose papers without corroboration by inquiry or leading to undisclosed assets cannot be basis for additions. Suspicion alone cannot replace evidence. AO failed to establish live link between seized material and unaccounted fees resulting in undisclosed assets. Uncorroborated seized material alone cannot be considered conclusive evidence. Presumption u/s 132(4) is rebuttable. AO should act judicially on adequate material, not arbitrarily. Additions cannot be made without examining concerned students/parents. Mere notes in diaries/loose sheets require corroboration. Non-speaking documents without corroborative evidence showing undisclosed income cannot be relied upon for additions.
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