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...
Rejection of application of the petitioner for refund - Writ petition filed instead of appeal before GST Tribunal - It needs no iteration that the Appellate Tribunal is the last fact finding authority and the aggrieved persons are deprived of their valuable statutory right due to non-availability of that forum. It is being made clear that if no satisfactory reply/compliance to the aforesaid directions is reflected in the counter affidavit, this Court may be constrained to summon the authorities concerned. - HC
Rejection of application of the petitioner for refund - Writ petition filed instead of appeal before GST Tribunal - It needs no iteration that the Appellate Tribunal is the last fact finding authority and the aggrieved persons are deprived of their valuable statutory right due to non-availability of that forum. It is being made clear that if no satisfactory reply/compliance to the aforesaid directions is reflected in the counter affidavit, this Court may be constrained to summon the authorities concerned. - HC
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