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...
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...
BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.
BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4908 
