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 - payment of CVD on MRP basis - Demand of differential duty of customs for the extended period of limitation, along with imposition of penalty - It is mentioned in the Show-Cause Notice that investigation was started by the department only after declaration of MRP/RSP suo moto by the appellant in the Bill of Entry filed in October, 2009 and subsequent Bills of Entry. - no case has been made of by the revenue that the appellant, in spite of having knowledge of such compliance towards MRP, have deliberately not declared. - the demand shall be limited to the normal period of limitation - AT
Valuation - payment of CVD on MRP basis - Demand of differential duty of customs for the extended period of limitation, along with imposition of penalty - It is mentioned in the Show-Cause Notice that investigation was started by the department only after declaration of MRP/RSP suo moto by the appellant in the Bill of Entry filed in October, 2009 and subsequent Bills of Entry. - no case has been made of by the revenue that the appellant, in spite of having knowledge of such compliance towards MRP, have deliberately not declared. - the demand shall be limited to the normal period of limitation - AT
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