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 SAD - denial of refund on the ground that the test of unjust enrichment not passed on - non-collection of excess duty paid by the appellant - The certificate of the Chartered Accountant would show that he has examined records and verified as to the details of the refund claim made by the appellant. Further, it is also shown that the amount was reflected in the accounts /balance sheet under the head ‘Customs Refund Receivables’. This would clearly go to establish that the excess duty has not been passed on to the buyers by the appellant Refund allowed - AT
Refund of SAD - denial of refund on the ground that the test of unjust enrichment not passed on - non-collection of excess duty paid by the appellant - The certificate of the Chartered Accountant would show that he has examined records and verified as to the details of the refund claim made by the appellant. Further, it is also shown that the amount was reflected in the accounts /balance sheet under the head ‘Customs Refund Receivables’. This would clearly go to establish that the excess duty has not been passed on to the buyers by the appellant Refund allowed - AT
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