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 set aside the impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
The HC set aside the impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
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TaxTMI 
TaxTMI 
of 4891 
