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...
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
