Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
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 ...
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Loan advanced in the ordinary course of business may generate an allowable revenue loss when waived under a settlement, provided it formed part of the taxpayer's commercial activities and neither acquired a capital asset nor represented a long-term capital investment. Financial participation through a shareholder-financier arrangement, repayable from business surplus, can retain its business character. The waiver was treated as incidental to business, distinguishable from an advance made to acquire immovable property, and the deduction was allowed.
Loan advanced in the ordinary course of business may generate an allowable revenue loss when waived under a settlement, provided it formed part of the taxpayer's commercial activities and neither acquired a capital asset nor represented a long-term capital investment. Financial participation through a shareholder-financier arrangement, repayable from business surplus, can retain its business character. The waiver was treated as incidental to business, distinguishable from an advance made to acquire immovable property, and the deduction was allowed.
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