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...
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...
Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.
Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.
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