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...
Inspection rights in regulatory adjudication extend to documents relied upon and forming part of the regulator's record, not blanket access to a bank's internal portal or electronic data outside that record. The prior rejection of inspection of non-record material had attained finality. Where the regulator confirmed it neither possessed nor would rely upon the requested data, and no specific documents were identified, unrestricted access risked disclosing confidential third-party information. The access direction was set aside, while the remaining directions continued.
Inspection rights in regulatory adjudication extend to documents relied upon and forming part of the regulator's record, not blanket access to a bank's internal portal or electronic data outside that record. The prior rejection of inspection of non-record material had attained finality. Where the regulator confirmed it neither possessed nor would rely upon the requested data, and no specific documents were identified, unrestricted access risked disclosing confidential third-party information. The access direction was set aside, while the remaining directions continued.
Note: It is a system-generated summary and is for quick reference only.