Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.
Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.
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