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...
Tariff rate quota benefits applied to qualifying imports of crude soybean oil, making refund of excess customs duty admissible. The position followed prior rulings concerning the same product and import period, and Revenue did not contest it. The refusal of refund was set aside, and the refund claim was required to be processed in accordance with law within three months.
Tariff rate quota benefits applied to qualifying imports of crude soybean oil, making refund of excess customs duty admissible. The position followed prior rulings concerning the same product and import period, and Revenue did not contest it. The refusal of refund was set aside, and the refund claim was required to be processed in accordance with law within three months.
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