Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
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Assessment proceedings conducted by non-jurisdictional officer - Assessee participated without challenging jurisdiction - Assessment order valid as per Supreme Court ruling in DCIT vs. Kalinga Institute case. Bogus expenses - Assessee provided incomplete addresses, similar PAN numbers for different vendors - Disallowance of Rs. 20 lakhs justified considering totality of facts, assessee's inability to substantiate expenses despite reasonable profit rate declared. Estimation of 25% profit by authorities not warranted.
Assessment proceedings conducted by non-jurisdictional officer - Assessee participated without challenging jurisdiction - Assessment order valid as per Supreme Court ruling in DCIT vs. Kalinga Institute case. Bogus expenses - Assessee provided incomplete addresses, similar PAN numbers for different vendors - Disallowance of Rs. 20 lakhs justified considering totality of facts, assessee's inability to substantiate expenses despite reasonable profit rate declared. Estimation of 25% profit by authorities not warranted.
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