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...
Valuation - disallowance of deduction from assessable value - deduction on interest on receivables and collection charges on the delay in payment for each invoice - In the remand proceedings, the Assistant Commissioner and the Commissioner (Appeals) were not required to examine whether the amount on ‘interest on receivables’ and ‘bank charges’ is inbuilt in the price, but yet they not only proceeded to examine it but recorded a finding against the appellant. - Further, when the earlier decision of tribunal on the same issue has attained finally, the contrary order cannot sustained - AT
Valuation - disallowance of deduction from assessable value - deduction on interest on receivables and collection charges on the delay in payment for each invoice - In the remand proceedings, the Assistant Commissioner and the Commissioner (Appeals) were not required to examine whether the amount on ‘interest on receivables’ and ‘bank charges’ is inbuilt in the price, but yet they not only proceeded to examine it but recorded a finding against the appellant. - Further, when the earlier decision of tribunal on the same issue has attained finally, the contrary order cannot sustained - AT
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