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...
Unexplained election expenditure based on a seized notebook requires proof that the document belongs to or is linked with the taxpayer and independent corroboration of its entries. A notebook recovered from separate commission-agent business premises, without the taxpayer's name, verification from named persons, or other correlation, does not by itself establish unexplained expenditure despite the statutory presumption for seized documents. Undated alleged campaign payments must be assessed in the year supported by campaign, polling, search, and entry-related facts; meeting-schedule dates do not establish the year of payment.
Unexplained election expenditure based on a seized notebook requires proof that the document belongs to or is linked with the taxpayer and independent corroboration of its entries. A notebook recovered from separate commission-agent business premises, without the taxpayer's name, verification from named persons, or other correlation, does not by itself establish unexplained expenditure despite the statutory presumption for seized documents. Undated alleged campaign payments must be assessed in the year supported by campaign, polling, search, and entry-related facts; meeting-schedule dates do not establish the year of payment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
