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...
Settlement under the Direct Tax Vivad Se Vishwas Scheme, 2020 was confined to the dispute from the original assessment, as confirmed by the declaration, Form No. 5 and Assessing Officer verification. Subsequently initiated reassessment proceedings did not fall within that settlement, so dismissal on the premise that the reassessment dispute stood settled was set aside. The reassessment addition for alleged bogus purchases was deleted because the identities of suppliers, transaction-wise details, invoices and supporting material were not disclosed, leaving no clear factual basis for the addition.
Settlement under the Direct Tax Vivad Se Vishwas Scheme, 2020 was confined to the dispute from the original assessment, as confirmed by the declaration, Form No. 5 and Assessing Officer verification. Subsequently initiated reassessment proceedings did not fall within that settlement, so dismissal on the premise that the reassessment dispute stood settled was set aside. The reassessment addition for alleged bogus purchases was deleted because the identities of suppliers, transaction-wise details, invoices and supporting material were not disclosed, leaving no clear factual basis for the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
