Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
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...
Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.
Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
