Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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...
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ECIR is an internal, non-statutory departmental record that neither initiates prosecution nor independently imposes penal consequences. A first-instance acquittal in a scheduled offence is not final absolution while subject to appeal and does not determine the legitimacy of separately seized assets. The PMLA's specialised adjudicatory and appellate mechanism governs property retention and confiscation; writ jurisdiction should not bypass it where disputed financial facts require evidentiary assessment. Material indicating contravention of another law must be shared with the relevant agency under section 66(2), independently of an acquittal in a distinct predicate proceeding. The writ petition was dismissed, leaving statutory remedies available.
ECIR is an internal, non-statutory departmental record that neither initiates prosecution nor independently imposes penal consequences. A first-instance acquittal in a scheduled offence is not final absolution while subject to appeal and does not determine the legitimacy of separately seized assets. The PMLA's specialised adjudicatory and appellate mechanism governs property retention and confiscation; writ jurisdiction should not bypass it where disputed financial facts require evidentiary assessment. Material indicating contravention of another law must be shared with the relevant agency under section 66(2), independently of an acquittal in a distinct predicate proceeding. The writ petition was dismissed, leaving statutory remedies available.
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