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...
For a Kachha Arhatia, sales made for principals in commission transactions are not the agent's turnover; only gross commission is relevant. A GST turnover figure therefore cannot be mechanically compared with income-tax-return turnover where reconciliation identifies own trading sales, commission income and intra-day trading profit. Rejection of audited books requires a specific defect affecting their correctness or completeness, and no such defect was identified. Gross-profit estimation without comparable cases, past history, or supporting material is arbitrary. The rejection of books and consequential profit estimation were unsustainable, and returned income was directed to be accepted.
For a Kachha Arhatia, sales made for principals in commission transactions are not the agent's turnover; only gross commission is relevant. A GST turnover figure therefore cannot be mechanically compared with income-tax-return turnover where reconciliation identifies own trading sales, commission income and intra-day trading profit. Rejection of audited books requires a specific defect affecting their correctness or completeness, and no such defect was identified. Gross-profit estimation without comparable cases, past history, or supporting material is arbitrary. The rejection of books and consequential profit estimation were unsustainable, and returned income was directed to be accepted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4908 
