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...
Maintainability of appeal - time limitation - appeal filed before Commissioner (Appeals) after a delay of 11 months - More time has been taken by the department for considering appellant’s request under the Scheme which finally was rejected. The appeal before Commissioner (Appeals) has also been within reasonable time. Commissioner (Appeals) himself has held that appellant otherwise has sufficient reason to reach him but beyond the time as prescribed under Section 35(C ) of Central Excise Act. - Delay condoned - AT
Maintainability of appeal - time limitation - appeal filed before Commissioner (Appeals) after a delay of 11 months - More time has been taken by the department for considering appellant’s request under the Scheme which finally was rejected. The appeal before Commissioner (Appeals) has also been within reasonable time. Commissioner (Appeals) himself has held that appellant otherwise has sufficient reason to reach him but beyond the time as prescribed under Section 35(C ) of Central Excise Act. - Delay condoned - AT
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