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...
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
