Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Under the Sabka Vishwas Scheme, a liability admitted during enquiry or investigation was not treated as final quantification of duty by itself. Eligibility required the duty payable in the pending matter to be quantified on or before the statutory cut-off date, and a partial admission during investigation could not satisfy that requirement. On that basis, the rejection of the declaration was upheld because the tax liability had not been finally quantified by 30.06.2019. The hearing before the Designated Committee arose only after eligibility was established, so no prior hearing was required where the declarant was ex facie ineligible.
Under the Sabka Vishwas Scheme, a liability admitted during enquiry or investigation was not treated as final quantification of duty by itself. Eligibility required the duty payable in the pending matter to be quantified on or before the statutory cut-off date, and a partial admission during investigation could not satisfy that requirement. On that basis, the rejection of the declaration was upheld because the tax liability had not been finally quantified by 30.06.2019. The hearing before the Designated Committee arose only after eligibility was established, so no prior hearing was required where the declarant was ex facie ineligible.
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