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...
Agricultural land located within municipal limits is a capital asset, while aerial-distance and population criteria apply only to land outside those limits. Municipal jurisdiction on the transfer date must be established through underlying official material rather than an unproduced report, requiring fresh verification. An agricultural-land reinvestment exemption may be claimed for the first time before the Tribunal where relevant facts are already on record, but depends on proof of prior agricultural use and the qualifying purpose of replacement land. Stamp-duty valuation adjustment on purchase also requires reconsideration after determining whether the taxpayer disputes the value. All issues require fresh adjudication after evidence and hearing.
Agricultural land located within municipal limits is a capital asset, while aerial-distance and population criteria apply only to land outside those limits. Municipal jurisdiction on the transfer date must be established through underlying official material rather than an unproduced report, requiring fresh verification. An agricultural-land reinvestment exemption may be claimed for the first time before the Tribunal where relevant facts are already on record, but depends on proof of prior agricultural use and the qualifying purpose of replacement land. Stamp-duty valuation adjustment on purchase also requires reconsideration after determining whether the taxpayer disputes the value. All issues require fresh adjudication after evidence and hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
