Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.
Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
