Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Delay in filing returns and audit reports for AYs 2018-19 to 2022-23 was sought to be condoned under s.119(2)(b) on the ground that statutory audit under the applicable cooperative law could not be completed within time due to non-availability of departmental auditors, a cause not attributable to the assessee. The Court held that "genuine hardship" and "sufficient cause" were established, and the authority erred by rejecting the request on a hyper-technical view of inordinate delay despite documentary material showing systemic default and completed audits. As denial would potentially deprive legitimate s.80P deductions (subject to scrutiny), the rejection order was set aside and a mandamus issued to permit filing of returns with audit reports. - HC
Delay in filing returns and audit reports for AYs 2018-19 to 2022-23 was sought to be condoned under s.119(2)(b) on the ground that statutory audit under the applicable cooperative law could not be completed within time due to non-availability of departmental auditors, a cause not attributable to the assessee. The Court held that "genuine hardship" and "sufficient cause" were established, and the authority erred by rejecting the request on a hyper-technical view of inordinate delay despite documentary material showing systemic default and completed audits. As denial would potentially deprive legitimate s.80P deductions (subject to scrutiny), the rejection order was set aside and a mandamus issued to permit filing of returns with audit reports. - HC
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TaxTMI 
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