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...
Reopening of a concluded scrutiny assessment beyond four years requires recorded reasons that independently demonstrate tangible material, a rational link to income escaping assessment, and the taxpayer's failure to make a full and true disclosure of primary facts. Recorded reasons containing factual errors and no connection between an alleged entry operator and the shareholder do not establish due application of mind or a valid reason to believe. Disclosure of shareholder details, banking particulars and confirmations satisfies the taxpayer's obligation; the taxpayer need not draw further factual or legal inferences for the Assessing Officer. The reopening and consequential reassessment were void ab initio and quashed.
Reopening of a concluded scrutiny assessment beyond four years requires recorded reasons that independently demonstrate tangible material, a rational link to income escaping assessment, and the taxpayer's failure to make a full and true disclosure of primary facts. Recorded reasons containing factual errors and no connection between an alleged entry operator and the shareholder do not establish due application of mind or a valid reason to believe. Disclosure of shareholder details, banking particulars and confirmations satisfies the taxpayer's obligation; the taxpayer need not draw further factual or legal inferences for the Assessing Officer. The reopening and consequential reassessment were void ab initio and quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
