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...
Validity of availing CENVAT credit of CVD paid on import of coal - The department argued that granting credit to buyers of imported coal, while domestic coal buyers couldn't avail of such credit, disrupts the level playing field. - A consistent view has been taken by the various Benches on the provisions of Rule 3(1) and the distinction between the customs notification and the central excise notification. There is no reason to take any contrary view in the present case - Credit cannot be denied - AT
Validity of availing CENVAT credit of CVD paid on import of coal - The department argued that granting credit to buyers of imported coal, while domestic coal buyers couldn't avail of such credit, disrupts the level playing field. - A consistent view has been taken by the various Benches on the provisions of Rule 3(1) and the distinction between the customs notification and the central excise notification. There is no reason to take any contrary view in the present case - Credit cannot be denied - AT
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