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...
Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.
Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
