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...
Pre-CIRP statutory income-tax claims not forming part of an approved resolution plan are treated as extinguished, preventing continuation of proceedings concerning those claims. This principle applies where a corporate debtor's successor entered the corporate insolvency resolution process, an approved resolution plan was not implemented, and liquidation followed. No material established admission of the Department's claims for the relevant assessment years in the resolution or liquidation proceedings; the connected Departmental appeals, assessee appeal, and cross-objection therefore did not survive.
Pre-CIRP statutory income-tax claims not forming part of an approved resolution plan are treated as extinguished, preventing continuation of proceedings concerning those claims. This principle applies where a corporate debtor's successor entered the corporate insolvency resolution process, an approved resolution plan was not implemented, and liquidation followed. No material established admission of the Department's claims for the relevant assessment years in the resolution or liquidation proceedings; the connected Departmental appeals, assessee appeal, and cross-objection therefore did not survive.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
