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...
Levy of GST - distinct person - support services - Export of services or not - place of supply of service - In the present case, the applicant is a company incorporated under the laws of India and the service recipient group company, NSKJ is incorporated under the laws of Japan and therefore are separate persons and would not be considered as “merely establishments of distinct persons”. - the “Place of Supply” of the service extended will be the place of availability of the vessel and not the place of service receiver, i.e., NSKJ, which is Japan. - AAR
Levy of GST - distinct person - support services - Export of services or not - place of supply of service - In the present case, the applicant is a company incorporated under the laws of India and the service recipient group company, NSKJ is incorporated under the laws of Japan and therefore are separate persons and would not be considered as “merely establishments of distinct persons”. - the “Place of Supply” of the service extended will be the place of availability of the vessel and not the place of service receiver, i.e., NSKJ, which is Japan. - AAR
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