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...
Foreign tax credit on foreign dividend income cannot be denied solely because the prescribed form was furnished after the original-return due date but before the revised return and the end of the assessment year. Where the governing statute imposes no filing deadline and the procedural rule neither links delay to denial nor lists delayed filing as a disqualifying circumstance, the filing requirement operates as directory. Rectification is available where processing annexures recognise foreign tax credit as available but the computation simultaneously records it as nil, since that internal inconsistency is a mistake apparent from the record. The credit is to be allowed, while the processing adjustment remains open to challenge.
Foreign tax credit on foreign dividend income cannot be denied solely because the prescribed form was furnished after the original-return due date but before the revised return and the end of the assessment year. Where the governing statute imposes no filing deadline and the procedural rule neither links delay to denial nor lists delayed filing as a disqualifying circumstance, the filing requirement operates as directory. Rectification is available where processing annexures recognise foreign tax credit as available but the computation simultaneously records it as nil, since that internal inconsistency is a mistake apparent from the record. The credit is to be allowed, while the processing adjustment remains open to challenge.
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