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...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
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Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
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