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...
Search-related information concerning alleged non-genuine purchases must be addressed through the statutory reassessment route applicable where material is found in another person's search. The ordinary procedure under section 148A cannot displace that route. Approval for an order under section 148A(d) does not substitute for the independent prior approval required before issuing a notice under section 148. Compliance with the prescribed jurisdictional procedure is mandatory, not procedural; non-compliance creates a foundational jurisdictional defect and renders the reassessment notice and consequential assessment liable to be quashed without determination of the underlying addition.
Search-related information concerning alleged non-genuine purchases must be addressed through the statutory reassessment route applicable where material is found in another person's search. The ordinary procedure under section 148A cannot displace that route. Approval for an order under section 148A(d) does not substitute for the independent prior approval required before issuing a notice under section 148. Compliance with the prescribed jurisdictional procedure is mandatory, not procedural; non-compliance creates a foundational jurisdictional defect and renders the reassessment notice and consequential assessment liable to be quashed without determination of the underlying addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
