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...
Jurisdiction to issue SCN - validity of appointment of officers of DGCEI as ‘Central Excise Officers’ having all India jurisdiction - Though the summons emanate from the office of the Deputy Director of Directorate General of Central Intelligence, the file is transferred to the competent authority. The show cause notice is issued by the proper officer. - The show cause notice is within the jurisdiction and not without, as contended. Therefore, the petitioner has to answer to the show cause notice and further proceedings to take place in accordance with law. - HC
Jurisdiction to issue SCN - validity of appointment of officers of DGCEI as ‘Central Excise Officers’ having all India jurisdiction - Though the summons emanate from the office of the Deputy Director of Directorate General of Central Intelligence, the file is transferred to the competent authority. The show cause notice is issued by the proper officer. - The show cause notice is within the jurisdiction and not without, as contended. Therefore, the petitioner has to answer to the show cause notice and further proceedings to take place in accordance with law. - HC
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