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...
Disallowance of a cost of improvement claimed in calculating short-term capital gains, merely because contractor-level documentation is incomplete, does not by itself establish misrepresentation or suppression. Where the improvement work is undisputed and the expenditure has been disclosed in the return and supporting particulars, the income cannot be treated as underreported as a consequence of misreporting. Contractor-level evidence may be unjustified for incidental capital expenditure outside the taxpayer's regular business. The penalty for underreported income under section 270A was quashed.
Disallowance of a cost of improvement claimed in calculating short-term capital gains, merely because contractor-level documentation is incomplete, does not by itself establish misrepresentation or suppression. Where the improvement work is undisputed and the expenditure has been disclosed in the return and supporting particulars, the income cannot be treated as underreported as a consequence of misreporting. Contractor-level evidence may be unjustified for incidental capital expenditure outside the taxpayer's regular business. The penalty for underreported income under section 270A was quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
