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...
Berry ratio is unsuitable as a profit level indicator for a jewellery manufacturer that bears material, inventory, price and manufacturing risks, because value-added expenses exclude material costs, capital deployment and risks; total cost is the more reliable base. Sales transfer-pricing adjustments based on that ratio were deleted. Notional interest on associated-enterprise receivables requires parity analysis against unrelated customers: where identical 180-day, interest-free credit terms applied, the adjustment was deleted. For a later year, verification was required and any interest confined to delays beyond 180 days at six-month LIBOR plus verified bank spread. Transfer-pricing adjustments could not be included in book profit contrary to binding directions.
Berry ratio is unsuitable as a profit level indicator for a jewellery manufacturer that bears material, inventory, price and manufacturing risks, because value-added expenses exclude material costs, capital deployment and risks; total cost is the more reliable base. Sales transfer-pricing adjustments based on that ratio were deleted. Notional interest on associated-enterprise receivables requires parity analysis against unrelated customers: where identical 180-day, interest-free credit terms applied, the adjustment was deleted. For a later year, verification was required and any interest confined to delays beyond 180 days at six-month LIBOR plus verified bank spread. Transfer-pricing adjustments could not be included in book profit contrary to binding directions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
