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...
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...
Rectification jurisdiction permits correction only of a patent, manifest or self-evident error, not reassessment of evidence or review of an earlier view. Claims that additions for alleged on-money receipts failed to consider seized material, related orders, a co-ordinate Bench decision and precedents on income extrapolation did not establish a mistake apparent from the record where those materials had been considered. The rectification applications therefore amounted to an impermissible review and were dismissed.
Rectification jurisdiction permits correction only of a patent, manifest or self-evident error, not reassessment of evidence or review of an earlier view. Claims that additions for alleged on-money receipts failed to consider seized material, related orders, a co-ordinate Bench decision and precedents on income extrapolation did not establish a mistake apparent from the record where those materials had been considered. The rectification applications therefore amounted to an impermissible review and were dismissed.
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