Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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...
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The Income Tax Appellate Tribunal (ITAT) held that the assessee's transactions involving purchases and sales on a High Seas Sales (HSS) basis did not constitute speculative transactions. The ITAT observed that under the Act, the term "speculation" focuses on whether the transactions involve actual delivery, transfer, or settlement. In the assessee's case, the entire transaction involved a process where delivery of goods took place, evidenced by documents like the Bill of Lading, which was not disputed by the revenue authorities. The ITAT found that the assessee physically purchased goods from a foreign seller, sold them to an importer while on high seas, and the ultimate buyer took delivery by filing the bill of entry and complying with customs formalities. Since the factual sequence of events and documentary evidence regarding the ultimate delivery were not disputed, the ITAT concluded that the transactions did not amount to speculation. Consequently, the assessee's appeal was allowed.
The Income Tax Appellate Tribunal (ITAT) held that the assessee's transactions involving purchases and sales on a High Seas Sales (HSS) basis did not constitute speculative transactions. The ITAT observed that under the Act, the term "speculation" focuses on whether the transactions involve actual delivery, transfer, or settlement. In the assessee's case, the entire transaction involved a process where delivery of goods took place, evidenced by documents like the Bill of Lading, which was not disputed by the revenue authorities. The ITAT found that the assessee physically purchased goods from a foreign seller, sold them to an importer while on high seas, and the ultimate buyer took delivery by filing the bill of entry and complying with customs formalities. Since the factual sequence of events and documentary evidence regarding the ultimate delivery were not disputed, the ITAT concluded that the transactions did not amount to speculation. Consequently, the assessee's appeal was allowed.
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