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...
Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
