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...
Sabka Vishwas (Legacy) Dispute Resolution Scheme, 2019 - SVLDRS - delay in payment due to adjustment of amounts paid by the insurance company against the payment under the scheme - The stand of the Respondents in this regard is clearly hyper technical and arbitrary. The further stand of the Respondents that the last date for payment has expired on 30.09.2020 is also not acceptable. The delay in receiving payment is on account of the refusal of the Respondent No.3 to adjust the compensation amount payable by the 6th Respondent against the crystallised due under the scheme. The 6th Respondent had also issued the discharge voucher on 29.9.2020 and as such it cannot be said that the offer to pay had not been made before the last date. - HC
Sabka Vishwas (Legacy) Dispute Resolution Scheme, 2019 - SVLDRS - delay in payment due to adjustment of amounts paid by the insurance company against the payment under the scheme - The stand of the Respondents in this regard is clearly hyper technical and arbitrary. The further stand of the Respondents that the last date for payment has expired on 30.09.2020 is also not acceptable. The delay in receiving payment is on account of the refusal of the Respondent No.3 to adjust the compensation amount payable by the 6th Respondent against the crystallised due under the scheme. The 6th Respondent had also issued the discharge voucher on 29.9.2020 and as such it cannot be said that the offer to pay had not been made before the last date. - HC
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