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...
Separately billed room-service food and beverages supplied in hotel rooms were treated as sales rather than restaurant services because hotel rooms were not restaurant premises and no evidence linked the charges to room-service value; the related service-tax demand was set aside. Exclusive liquor-brand listing, displays and branded accessories constituted taxable promotional or sponsorship service, leaving that demand sustainable only within the normal limitation period. Actual electricity charges recovered from tenants on sub-meter readings and remitted to suppliers were not consideration for renting, so the demand was set aside. Extended limitation required deliberate evasion, not mere non-declaration; the surviving demand was restricted to the normal period.
Separately billed room-service food and beverages supplied in hotel rooms were treated as sales rather than restaurant services because hotel rooms were not restaurant premises and no evidence linked the charges to room-service value; the related service-tax demand was set aside. Exclusive liquor-brand listing, displays and branded accessories constituted taxable promotional or sponsorship service, leaving that demand sustainable only within the normal limitation period. Actual electricity charges recovered from tenants on sub-meter readings and remitted to suppliers were not consideration for renting, so the demand was set aside. Extended limitation required deliberate evasion, not mere non-declaration; the surviving demand was restricted to the normal period.
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