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...
Amounts paid under protest during provisional assessment were treated as revenue deposits, not duty, so Section 11B/11BB did not govern the refund or delay interest. Because the payment never acquired the character of duty and no pre-existing quantified liability existed, interest ran from each date of deposit until actual refund, not three months after the refund claim. The Tribunal also held that the proper rate was 12% per annum, with interest already paid to be adjusted.
Amounts paid under protest during provisional assessment were treated as revenue deposits, not duty, so Section 11B/11BB did not govern the refund or delay interest. Because the payment never acquired the character of duty and no pre-existing quantified liability existed, interest ran from each date of deposit until actual refund, not three months after the refund claim. The Tribunal also held that the proper rate was 12% per annum, with interest already paid to be adjusted.
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