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...
GTA service or not - The adjudicating authority while declining the transportation activity as a GTA service has held that since there is no consignment note, the same cannot be held to be the GTA service. - No doubt in terms of Rule 4B of Service Tax Rule, 1994, issuance of consignment note to the recipient of service is mandatory. But in the present case, apparently and admittedly, there were issued transit slips having all such details as were to be mentioned in the consignment note. Hence just because the receipts/notes had a different nomenclature, it cannot be held that there was no consignment note. - AT
GTA service or not - The adjudicating authority while declining the transportation activity as a GTA service has held that since there is no consignment note, the same cannot be held to be the GTA service. - No doubt in terms of Rule 4B of Service Tax Rule, 1994, issuance of consignment note to the recipient of service is mandatory. But in the present case, apparently and admittedly, there were issued transit slips having all such details as were to be mentioned in the consignment note. Hence just because the receipts/notes had a different nomenclature, it cannot be held that there was no consignment note. - AT
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