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...
Disallowance of credit - With regard to the payment of service tax made by Unit No. II, since the said unit is centralized registered, Unit No. II is under obligation to pay the service tax on behalf of all the units. Merely because, the Unit No. II has paid the service tax, the eligibility of cenvat credit of the present appellant’s unit will not adversely be affected because irrespective of any unit paying the service tax, all the units are under one single entity - AT
Disallowance of credit - With regard to the payment of service tax made by Unit No. II, since the said unit is centralized registered, Unit No. II is under obligation to pay the service tax on behalf of all the units. Merely because, the Unit No. II has paid the service tax, the eligibility of cenvat credit of the present appellant’s unit will not adversely be affected because irrespective of any unit paying the service tax, all the units are under one single entity - AT
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