Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Non-genuine metal purchases with undisputed corresponding sales warrant an addition only for the profit element embedded in those purchases, rather than their full value. ITAT treated the business and dispute as materially similar to the immediately preceding year and, as Revenue showed no material factual difference, followed the prior-year estimation. The addition was reduced from 12.5% to 5% of the disputed purchases. Reopening grounds remained open, and consequential interest was to be recomputed.
Non-genuine metal purchases with undisputed corresponding sales warrant an addition only for the profit element embedded in those purchases, rather than their full value. ITAT treated the business and dispute as materially similar to the immediately preceding year and, as Revenue showed no material factual difference, followed the prior-year estimation. The addition was reduced from 12.5% to 5% of the disputed purchases. Reopening grounds remained open, and consequential interest was to be recomputed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
