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...
Gold seizure requires a pre-existing, objectively sustainable reasonable belief that goods are liable to confiscation; a statutory burden to establish licit acquisition cannot retrospectively cure the absence of that foundation. Foreign origin and illicit importation require reliable evidence beyond concealment, missing documents at interception, or general smuggling intelligence; traceable stock, purchase, inheritance and melting records must be properly tested. A retracted customs statement cannot substantively establish smuggling without corroboration and applicable procedural safeguards, especially where investigative material contradicts it. Penalty requires independent proof of each person's conscious act or omission and the requisite knowledge or intent.
Gold seizure requires a pre-existing, objectively sustainable reasonable belief that goods are liable to confiscation; a statutory burden to establish licit acquisition cannot retrospectively cure the absence of that foundation. Foreign origin and illicit importation require reliable evidence beyond concealment, missing documents at interception, or general smuggling intelligence; traceable stock, purchase, inheritance and melting records must be properly tested. A retracted customs statement cannot substantively establish smuggling without corroboration and applicable procedural safeguards, especially where investigative material contradicts it. Penalty requires independent proof of each person's conscious act or omission and the requisite knowledge or intent.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
