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...
Clandestine Removal - Confectionery Items - this manufacturer was availing SSI exemption benefit due to which there was no necessity to prepare the statutory records. The department had put no effort to examine the computerized records. There is no evidence even about any cash flow which may prove the element of any mens rea / bad intention to evade the duty, question of imposition of penalty does not at all arise. - AT
Clandestine Removal - Confectionery Items - this manufacturer was availing SSI exemption benefit due to which there was no necessity to prepare the statutory records. The department had put no effort to examine the computerized records. There is no evidence even about any cash flow which may prove the element of any mens rea / bad intention to evade the duty, question of imposition of penalty does not at all arise. - AT
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