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...
On-money forming part of consideration for sale of flats accrues when the sale deed is executed and title transfers, rather than on mere receipt as an advance, under the project-completion method. Disclosed on-money offered in the respective years of sale-deed registration cannot be taxed wholly in the earlier assessment year without verifying later-year tax offerings. Balance additions require limited verification of income offered within the stipulated undertaking periods; verified amounts must be deleted, while amounts not offered may be taxed in the earlier year. No further deferment beyond those stipulated periods is permitted.
On-money forming part of consideration for sale of flats accrues when the sale deed is executed and title transfers, rather than on mere receipt as an advance, under the project-completion method. Disclosed on-money offered in the respective years of sale-deed registration cannot be taxed wholly in the earlier assessment year without verifying later-year tax offerings. Balance additions require limited verification of income offered within the stipulated undertaking periods; verified amounts must be deleted, while amounts not offered may be taxed in the earlier year. No further deferment beyond those stipulated periods is permitted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
