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...
Customs adjudication orders require challenges to determinations, related bank guarantees, and alleged adjudicatory delay to be pursued before the statutory appellate forum in the first instance. A direction to defer matters involving delay in adjudication does not extend to a writ where Orders-in-Original have already been issued; the dispute is no longer one concerning pending adjudication. Relief restraining finalisation of provisional assessments becomes infructuous after adjudication. In the absence of exceptional circumstances, writ jurisdiction cannot bypass the appellate remedy, and non-disclosure of a material prior adjudication order affects writ relief. The merits of the orders and consequences of alleged delay remain open before the appellate authority.
Customs adjudication orders require challenges to determinations, related bank guarantees, and alleged adjudicatory delay to be pursued before the statutory appellate forum in the first instance. A direction to defer matters involving delay in adjudication does not extend to a writ where Orders-in-Original have already been issued; the dispute is no longer one concerning pending adjudication. Relief restraining finalisation of provisional assessments becomes infructuous after adjudication. In the absence of exceptional circumstances, writ jurisdiction cannot bypass the appellate remedy, and non-disclosure of a material prior adjudication order affects writ relief. The merits of the orders and consequences of alleged delay remain open before the appellate authority.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4901 
