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...
Omission of Rule 96(10) without a saving clause requires pending claims for refund of integrated tax paid on exports to be assessed without the former eligibility restriction. The Supreme Court treated the omission as applicable to proceedings pending on 08 October 2024, because no provision preserved the omitted sub-rule. Section 6 of the General Clauses Act does not save proceedings under an omitted rule, as it applies to repeal by a Central Act or Regulation rather than subordinate legislation. Independent refund conditions under the zero-rated supply, Section 54 and Rule 96 framework, including applicable procedures and limitation, continue to govern refund entitlement.
Omission of Rule 96(10) without a saving clause requires pending claims for refund of integrated tax paid on exports to be assessed without the former eligibility restriction. The Supreme Court treated the omission as applicable to proceedings pending on 08 October 2024, because no provision preserved the omitted sub-rule. Section 6 of the General Clauses Act does not save proceedings under an omitted rule, as it applies to repeal by a Central Act or Regulation rather than subordinate legislation. Independent refund conditions under the zero-rated supply, Section 54 and Rule 96 framework, including applicable procedures and limitation, continue to govern refund entitlement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
