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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FEMA adjudication concerning under-invoiced imports remains independent of Customs valuation and duty proceedings, and statements recorded under the Customs Act may be considered. Seized electronic records carry a rebuttable presumption of truth where their integrity is established; unrebutted records and related statements can prove foreign-exchange contraventions on a preponderance-of-probabilities standard. Contraventions may be sustained for documented import entries, but projections or extrapolations from electronic data require corroborative evidence and cannot alone support allegations. A person in charge of a company is personally liable for established corporate contraventions to the same evidence-based extent.
FEMA adjudication concerning under-invoiced imports remains independent of Customs valuation and duty proceedings, and statements recorded under the Customs Act may be considered. Seized electronic records carry a rebuttable presumption of truth where their integrity is established; unrebutted records and related statements can prove foreign-exchange contraventions on a preponderance-of-probabilities standard. Contraventions may be sustained for documented import entries, but projections or extrapolations from electronic data require corroborative evidence and cannot alone support allegations. A person in charge of a company is personally liable for established corporate contraventions to the same evidence-based extent.
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