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...
Non-fulfilment of export obligation under Advance Authorization by importer company. Penalty imposed on directors solely based on their shareholding and directorship, without establishing their role in the alleged offence. Separate proceedings already initiated against the company for duty-free import and non-fulfilment. Penalty u/s 112(a) and (b) of Customs Act imposed together, legally unsustainable. Ingredients for imposing penalty u/s 112 not existing. Penalties on directors set aside by Appellate Tribunal as unsustainable.
Non-fulfilment of export obligation under Advance Authorization by importer company. Penalty imposed on directors solely based on their shareholding and directorship, without establishing their role in the alleged offence. Separate proceedings already initiated against the company for duty-free import and non-fulfilment. Penalty u/s 112(a) and (b) of Customs Act imposed together, legally unsustainable. Ingredients for imposing penalty u/s 112 not existing. Penalties on directors set aside by Appellate Tribunal as unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
