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...
Faceless assessment permits Assessment Units to exercise Assessing Officer functions, including issuing scrutiny notices, without requiring the National Faceless Assessment Centre to issue them. ESOP discount reimbursed to a holding company constitutes employee compensation accruing over the vesting period where the liability has arisen and is reasonably estimable; later exercise, lapses or forfeitures require corresponding adjustments. A disallowance for failure to deduct tax from settlement compensation requires an identified statutory withholding obligation. Relinquishment of a right to sue does not itself establish payment for services, commission, brokerage, professional or technical services, or a non-compete arrangement; for non-resident payments, withholding depends on taxability in India.
Faceless assessment permits Assessment Units to exercise Assessing Officer functions, including issuing scrutiny notices, without requiring the National Faceless Assessment Centre to issue them. ESOP discount reimbursed to a holding company constitutes employee compensation accruing over the vesting period where the liability has arisen and is reasonably estimable; later exercise, lapses or forfeitures require corresponding adjustments. A disallowance for failure to deduct tax from settlement compensation requires an identified statutory withholding obligation. Relinquishment of a right to sue does not itself establish payment for services, commission, brokerage, professional or technical services, or a non-compete arrangement; for non-resident payments, withholding depends on taxability in India.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
