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 HC dismissed the petition and upheld the validity of the impugned show-cause notice issued to the transferor company, holding that the notice is not shown to be wholly without jurisdiction; factual and jurisdictional questions relating to the demerger and retrospective operation of the 2018 Notification require examination and cannot be summarily struck down. The Respondents are entitled to consider the demerger particulars and the applicability of the 2018 Notification when adjudicating the SCN, and the Petitioners are relegated to file a detailed response with full particulars and exhaust statutory remedies. The court found no exceptional circumstance to preclude adjudication or to quash the SCN at the threshold.
The HC dismissed the petition and upheld the validity of the impugned show-cause notice issued to the transferor company, holding that the notice is not shown to be wholly without jurisdiction; factual and jurisdictional questions relating to the demerger and retrospective operation of the 2018 Notification require examination and cannot be summarily struck down. The Respondents are entitled to consider the demerger particulars and the applicability of the 2018 Notification when adjudicating the SCN, and the Petitioners are relegated to file a detailed response with full particulars and exhaust statutory remedies. The court found no exceptional circumstance to preclude adjudication or to quash the SCN at the threshold.
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TaxTMI 
TaxTMI 
of 4894 
