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...
Scope of SCN - The SCN has raised objection only with regard to aspect of unjust enrichment, Whereas, the Adjudicating Authority as well as the Ld. Commissioner (Appeals) had gone into the aspect of nature of services, whether the services fall under works contract service or otherwise - Such an important issue cannot be dealt without making any allegations in the SCN - not permissible
Scope of SCN - The SCN has raised objection only with regard to aspect of unjust enrichment, Whereas, the Adjudicating Authority as well as the Ld. Commissioner (Appeals) had gone into the aspect of nature of services, whether the services fall under works contract service or otherwise - Such an important issue cannot be dealt without making any allegations in the SCN - not permissible
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