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...
Reassessment of a loan credit previously examined in scrutiny cannot rest on the same confirmation, bank statements and balance sheet without fresh information or tangible material; adopting a different view is an impermissible change of opinion. Separately, an electronic notice served on or after 1 April 2021 must follow section 148A: a show-cause notice, supply of material, consideration of the taxpayer's reply, and an order before issuing a notice under section 148. Failure to follow this sequence invalidates reassessment. On these independent grounds, the reassessment notice and consequential order were quashed, without deciding the loan-credit addition on merits.
Reassessment of a loan credit previously examined in scrutiny cannot rest on the same confirmation, bank statements and balance sheet without fresh information or tangible material; adopting a different view is an impermissible change of opinion. Separately, an electronic notice served on or after 1 April 2021 must follow section 148A: a show-cause notice, supply of material, consideration of the taxpayer's reply, and an order before issuing a notice under section 148. Failure to follow this sequence invalidates reassessment. On these independent grounds, the reassessment notice and consequential order were quashed, without deciding the loan-credit addition on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
