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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Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
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