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 Service of notice u/s 74(5) instead of u/s 74(1) of CGST / UPGST Act, 2017 - Non-payment of Tax / GST - The High Court observed that while a notice was issued to the petitioner under Section 74(5) of the Act on June 4, 2021, asserting tax liability, the procedure mandated by Section 74(7) of the Act, which requires issuance of a show cause notice under Section 74(1) upon non-payment of tax, was not followed. Given the failure to issue a proper show cause notice to the petitioner, the court concluded that the impugned orders lacked a legal basis.
Validity of Service of notice u/s 74(5) instead of u/s 74(1) of CGST / UPGST Act, 2017 - Non-payment of Tax / GST - The High Court observed that while a notice was issued to the petitioner under Section 74(5) of the Act on June 4, 2021, asserting tax liability, the procedure mandated by Section 74(7) of the Act, which requires issuance of a show cause notice under Section 74(1) upon non-payment of tax, was not followed. Given the failure to issue a proper show cause notice to the petitioner, the court concluded that the impugned orders lacked a legal basis.
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