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...
Rejection of refund of penalty deposited - applicability of principles of unjust enrichment - the provisions of unjust enrichment are not attracted as the burden of penalty is borne by the appellant and has not been passed on to their service receivers. Moreover, it is found that the refund arising pursuant to being successful in appeal, is available to an assessee under the provisions of Section 35 FF of the Central Excise Act. - AT
Rejection of refund of penalty deposited - applicability of principles of unjust enrichment - the provisions of unjust enrichment are not attracted as the burden of penalty is borne by the appellant and has not been passed on to their service receivers. Moreover, it is found that the refund arising pursuant to being successful in appeal, is available to an assessee under the provisions of Section 35 FF of the Central Excise Act. - AT
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