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...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Section 24(1)(a) of the 2013 Act applies where acquisition proceedings began under the 1894 Act but the award was made after the 2013 Act commenced; compensation must then be determined under the 2013 Act, while rehabilitation and resettlement entitlements are not retrospectively imported. Appeals from such awards are treated as first appeals under Section 74 of the 2013 Act, not under Section 54 of the 1894 Act. Section 74 does not expressly or impliedly exclude Section 5 of the Limitation Act, and Section 29(2) therefore permits condonation of delay. The delay in the first appeals was condoned, the contrary High Court rulings were set aside, and the matters were directed to proceed on merits.
Section 24(1)(a) of the 2013 Act applies where acquisition proceedings began under the 1894 Act but the award was made after the 2013 Act commenced; compensation must then be determined under the 2013 Act, while rehabilitation and resettlement entitlements are not retrospectively imported. Appeals from such awards are treated as first appeals under Section 74 of the 2013 Act, not under Section 54 of the 1894 Act. Section 74 does not expressly or impliedly exclude Section 5 of the Limitation Act, and Section 29(2) therefore permits condonation of delay. The delay in the first appeals was condoned, the contrary High Court rulings were set aside, and the matters were directed to proceed on merits.
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TaxTMI 
TaxTMI 
of 4897 
