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...
Challenge to search and seizure under the CGST regime centred on whether cash qualifies as "goods" or as "documents or books or things" under Section 67; the court held the statutory definition of goods excludes money and reading "things" ejusdem generis with "documents" and "books" limits it to evidentiary items containing information. Cash may be seized only where specific notes or currency can be shown to have direct evidentiary value traceable to taxable transactions. On the facts, authorities failed to establish evidentiary necessity; the cash was ordered de-sealed and released, while broader validity of the search was left for further affidavit exchange and hearing with interim procedural restraints.
Challenge to search and seizure under the CGST regime centred on whether cash qualifies as "goods" or as "documents or books or things" under Section 67; the court held the statutory definition of goods excludes money and reading "things" ejusdem generis with "documents" and "books" limits it to evidentiary items containing information. Cash may be seized only where specific notes or currency can be shown to have direct evidentiary value traceable to taxable transactions. On the facts, authorities failed to establish evidentiary necessity; the cash was ordered de-sealed and released, while broader validity of the search was left for further affidavit exchange and hearing with interim procedural restraints.
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