Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
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...
Recovery/reversal of credit - Export of Goods - Credit was availed under Rule 16 on returned Goods - The view taken by the authorities below is that reversal of the credit availed under Rule 16 is a pre-condition for removal of the said goods and therefore, the appellant has to reverse the credit. It is also alleged that when the goods were not originally meant for export, it cannot be later exported when the goods are brought back to the factory under Rule 16 - the said view of the Commissioner (Appeals) cannot be endorsed upon. - AT
Recovery/reversal of credit - Export of Goods - Credit was availed under Rule 16 on returned Goods - The view taken by the authorities below is that reversal of the credit availed under Rule 16 is a pre-condition for removal of the said goods and therefore, the appellant has to reverse the credit. It is also alleged that when the goods were not originally meant for export, it cannot be later exported when the goods are brought back to the factory under Rule 16 - the said view of the Commissioner (Appeals) cannot be endorsed upon. - AT
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