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...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
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Revisional jurisdiction over concurrent cheque-dishonour convictions is supervisory, not a second appellate review of evidence, and interference requires perversity, patent illegality, or miscarriage of justice. Admission of a signed cheque, including where it is alleged to have been delivered blank, triggers presumptions of consideration and legally enforceable liability; inconsistent or unsupported explanations do not establish a probable defence. Unchallenged bank evidence may prove dishonour, while a signed acknowledgement proves actual service of the statutory demand notice without recourse to deemed service. Custodial sentence and compensation may be sustained where they reflect the deterrent purpose of the offence and compensate for loss of use of funds and prosecution expenses.
Revisional jurisdiction over concurrent cheque-dishonour convictions is supervisory, not a second appellate review of evidence, and interference requires perversity, patent illegality, or miscarriage of justice. Admission of a signed cheque, including where it is alleged to have been delivered blank, triggers presumptions of consideration and legally enforceable liability; inconsistent or unsupported explanations do not establish a probable defence. Unchallenged bank evidence may prove dishonour, while a signed acknowledgement proves actual service of the statutory demand notice without recourse to deemed service. Custodial sentence and compensation may be sustained where they reflect the deterrent purpose of the offence and compensate for loss of use of funds and prosecution expenses.
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