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...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
The HC determined that the Corporation's withholding of royalty payment from the petitioner's work bill was conditional. The petitioner was granted liberty to submit a complete claim with all information requested in Annexure 'R/B' within two months. Upon receipt of the complete claim, the Corporation must consider it in accordance with law and Standard Bidding Document Clause 35. The Court clarified that the prima-facie opinion expressed in paragraph 4 of the Letter (Annexure 'R/B') should not impede fair consideration of the claim. The Corporation agreed to consider the petitioner's GST claim amount subject to submission of complete documentation. Application disposed of.
The HC determined that the Corporation's withholding of royalty payment from the petitioner's work bill was conditional. The petitioner was granted liberty to submit a complete claim with all information requested in Annexure 'R/B' within two months. Upon receipt of the complete claim, the Corporation must consider it in accordance with law and Standard Bidding Document Clause 35. The Court clarified that the prima-facie opinion expressed in paragraph 4 of the Letter (Annexure 'R/B') should not impede fair consideration of the claim. The Corporation agreed to consider the petitioner's GST claim amount subject to submission of complete documentation. Application disposed of.
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TaxTMI 
TaxTMI 
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