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...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
The High Court dismissed the application filed by the plaintiffs seeking an order to require the defendants to secure an amount of Rs. 1,14,88,833/- until the disposal of the suit. The Court held that the plaintiffs failed to establish a prima facie case against the defendants to demonstrate that they were attempting to dispose of or remove movable or immovable properties from the Court's jurisdiction to prevent the plaintiffs from realizing any decretal amount that may be awarded in the future. The Court found that the plaintiffs merely made a bald statement about apprehending the defendants' potential actions, without providing any supporting documents. The dispute over the principal amount of Rs. 77,05,223/- claimed by the plaintiffs, along with interest at 18% per annum, and the defendants' defense of having returned goods worth Rs. 55,24,252/- to the plaintiff company, remains a matter for trial.
The High Court dismissed the application filed by the plaintiffs seeking an order to require the defendants to secure an amount of Rs. 1,14,88,833/- until the disposal of the suit. The Court held that the plaintiffs failed to establish a prima facie case against the defendants to demonstrate that they were attempting to dispose of or remove movable or immovable properties from the Court's jurisdiction to prevent the plaintiffs from realizing any decretal amount that may be awarded in the future. The Court found that the plaintiffs merely made a bald statement about apprehending the defendants' potential actions, without providing any supporting documents. The dispute over the principal amount of Rs. 77,05,223/- claimed by the plaintiffs, along with interest at 18% per annum, and the defendants' defense of having returned goods worth Rs. 55,24,252/- to the plaintiff company, remains a matter for trial.
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