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...
Refund of CENVAT Credit reversed - it is seen that the appellants have voluntarily reversed the Cenvat Credit and now are seeking the refund. There is no provision for granting refund of any Cenvat credit voluntarily reversed by the appellant - Refund of any credit can only be granted when it is sanctioned by law and there are specific provisions for it. - AT
Refund of CENVAT Credit reversed - it is seen that the appellants have voluntarily reversed the Cenvat Credit and now are seeking the refund. There is no provision for granting refund of any Cenvat credit voluntarily reversed by the appellant - Refund of any credit can only be granted when it is sanctioned by law and there are specific provisions for it. - AT
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