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...
Transitional Input tax credit - availment of accumulated CENVAT by filing declaration Form TRAN-1 beyond the period provided under CGST Rules - Rule 117 is directory in nature, insofar as it prescribes the time-limit for transitioning of credit and therefore, the same would not result in the forfeiture of the rights, in case the credit is not availed within the period prescribed - the period of three years should be the guiding principle and thus a period of three years from the appointed date would be the maximum period for availing of such credit.
Transitional Input tax credit - availment of accumulated CENVAT by filing declaration Form TRAN-1 beyond the period provided under CGST Rules - Rule 117 is directory in nature, insofar as it prescribes the time-limit for transitioning of credit and therefore, the same would not result in the forfeiture of the rights, in case the credit is not availed within the period prescribed - the period of three years should be the guiding principle and thus a period of three years from the appointed date would be the maximum period for availing of such credit.
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