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...
Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.
Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.
Note: It is a system-generated summary and is for quick reference only.