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 - non-inclusion of certain expenses incurred by the service recipient - Insurance Auxiliary Services - Illegal recovery of service tax from the insurance agent - though, it can be argue, that the expenses on pre- recruitment training/ re-furbisher training should have been born by the agents themselves in order to obtain a license from the Regulatory Authority, the explanation to Section 67 as above does not provide for inclusion of any expenditure that could have been borne by the service providers - AT
Valuation - non-inclusion of certain expenses incurred by the service recipient - Insurance Auxiliary Services - Illegal recovery of service tax from the insurance agent - though, it can be argue, that the expenses on pre- recruitment training/ re-furbisher training should have been born by the agents themselves in order to obtain a license from the Regulatory Authority, the explanation to Section 67 as above does not provide for inclusion of any expenditure that could have been borne by the service providers - AT
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