Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Penalty under section 270A for alleged misreporting based on estimated gross profit additions could not be sustained where the Revenue relied on third-party electronic records seized in search without independent corroboration. The Tribunal held that the burden remained on the Revenue to substantiate the unmatched entries, and the assessee was not required to prove a negative. It also found that statements linked to the searched person could not be used conclusively against the assessee without corroborative material and cross-examination, and that the J-Pack ledger itself contained discrepancies. The penalties were deleted for all captioned assessment years, while the jurisdictional challenge to the section 153C assessment was left open.
Penalty under section 270A for alleged misreporting based on estimated gross profit additions could not be sustained where the Revenue relied on third-party electronic records seized in search without independent corroboration. The Tribunal held that the burden remained on the Revenue to substantiate the unmatched entries, and the assessee was not required to prove a negative. It also found that statements linked to the searched person could not be used conclusively against the assessee without corroborative material and cross-examination, and that the J-Pack ledger itself contained discrepancies. The penalties were deleted for all captioned assessment years, while the jurisdictional challenge to the section 153C assessment was left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
