Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Waiver of Penalty - Section 149 permits reassessment only in the circumstances and on the strength of “documentary evidence which was in existence at the time goods were cleared, deposited or exported”. It is not clear that country of origin certificate were available at the time of clearance of goods - appellants have correctly described the product in the bills of entry and claimed the notification - no penalty
Waiver of Penalty - Section 149 permits reassessment only in the circumstances and on the strength of “documentary evidence which was in existence at the time goods were cleared, deposited or exported”. It is not clear that country of origin certificate were available at the time of clearance of goods - appellants have correctly described the product in the bills of entry and claimed the notification - no penalty
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