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...
Availability of benefit of exemption subject to conditions - the appellants have availed the exemption contained in Notification No.06/2006 dated 01.03.2006 only after the receipt of a Certificate issued by the jurisdictional Deputy Commissioner, in charge of their customer. The Department has not got the Certificate nullified/ modified/ withdrawn. - Duty cannot be demanded from the appellants - AT
Availability of benefit of exemption subject to conditions - the appellants have availed the exemption contained in Notification No.06/2006 dated 01.03.2006 only after the receipt of a Certificate issued by the jurisdictional Deputy Commissioner, in charge of their customer. The Department has not got the Certificate nullified/ modified/ withdrawn. - Duty cannot be demanded from the appellants - AT
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