Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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.
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