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...
Voluntary payments by a partnership firm towards an outstanding tax demand of one partner were not treated as forced recovery merely because the firm's bank account had been attached. The firm did not establish that the Department had been notified of its change from proprietorship to partnership before payment. Claims arising from payment of a partner's liability constituted inter se disputes among partners and did not demonstrate illegality, error, or arbitrariness in the Department's action. The refund claim was denied and the writ petition dismissed.
Voluntary payments by a partnership firm towards an outstanding tax demand of one partner were not treated as forced recovery merely because the firm's bank account had been attached. The firm did not establish that the Department had been notified of its change from proprietorship to partnership before payment. Claims arising from payment of a partner's liability constituted inter se disputes among partners and did not demonstrate illegality, error, or arbitrariness in the Department's action. The refund claim was denied and the writ petition dismissed.
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TaxTMI 
TaxTMI 
of 4915 
