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...
Delayed furnishing of a statement of financial transactions may attract penalty, but belated filing alone does not exclude the statutory defence of reasonable cause. Penalty should not be sustained without examining the taxpayer's explanation and supporting evidence for the delay. Where the first appellate authority has dismissed the matter without deciding the grounds on merits or considering reasonable cause, it should provide due opportunity, examine that defence, and determine the penalty afresh in accordance with law.
Delayed furnishing of a statement of financial transactions may attract penalty, but belated filing alone does not exclude the statutory defence of reasonable cause. Penalty should not be sustained without examining the taxpayer's explanation and supporting evidence for the delay. Where the first appellate authority has dismissed the matter without deciding the grounds on merits or considering reasonable cause, it should provide due opportunity, examine that defence, and determine the penalty afresh in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4908 
