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...
Imposition of penalty u/r 15(2) of CCR, 2004 - CENVAT Credit - No evidence of fraud, collusion, wilful misstatement, suppression of facts which are essential conditions for imposition of penalty under Rule 15(2) of CCR, 2004 are evident either from the SCN or from the impugned order - the penalty imposed upon assessee under Rule 15(2) of CCR, 2004 is set aside. - AT
Imposition of penalty u/r 15(2) of CCR, 2004 - CENVAT Credit - No evidence of fraud, collusion, wilful misstatement, suppression of facts which are essential conditions for imposition of penalty under Rule 15(2) of CCR, 2004 are evident either from the SCN or from the impugned order - the penalty imposed upon assessee under Rule 15(2) of CCR, 2004 is set aside. - AT
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