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...
Validity of Arbitral Award - neglected to furnish the Form-Cs within the time prescribed resulting in a sales tax assessment - penalty imposed under the ‘Take or Pay/Supply or Pay’ Clause - HPCL had delayed in filing its counter claim, which was filed along with its sur-rejoinder after the pleadings were complete. The application to make an amendment was moved at the stage of final hearing of the claims. Undeniably, the same was at a much belated stage. Thus, the decision of the Arbitral Tribunal to deny HPCL’s request to amend the claim cannot be faulted. - HC
Validity of Arbitral Award - neglected to furnish the Form-Cs within the time prescribed resulting in a sales tax assessment - penalty imposed under the ‘Take or Pay/Supply or Pay’ Clause - HPCL had delayed in filing its counter claim, which was filed along with its sur-rejoinder after the pleadings were complete. The application to make an amendment was moved at the stage of final hearing of the claims. Undeniably, the same was at a much belated stage. Thus, the decision of the Arbitral Tribunal to deny HPCL’s request to amend the claim cannot be faulted. - HC
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