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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Uncorroborated statements recorded during a survey cannot alone support an addition for estimated income as unexplained money where no unrecorded money or specified valuable article is found, audited books are not shown incorrect, and no incriminating material exists. The addition was deleted. Delayed electronic furnishing of a tax audit report may constitute reasonable cause when accounts were audited and the report signed within time, but uploading was omitted due to the auditor's illness, without intent to evade tax. The related penalty was deleted.
Uncorroborated statements recorded during a survey cannot alone support an addition for estimated income as unexplained money where no unrecorded money or specified valuable article is found, audited books are not shown incorrect, and no incriminating material exists. The addition was deleted. Delayed electronic furnishing of a tax audit report may constitute reasonable cause when accounts were audited and the report signed within time, but uploading was omitted due to the auditor's illness, without intent to evade tax. The related penalty was deleted.
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