Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
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...
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Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128's timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.
Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128's timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.
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