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...
Undervaluation - Imports of high-end foreign cars - The appellate tribunal noted that the assessable value was determined using various sources, including the car manufacturer's website and internet values. However, crucial information, such as Alberto's retracted statement and documentary evidence, was not adequately considered. The tribunal observed discrepancies in the invoices and highlighted the lack of evidence supporting the revenue's allegations of under-valuation. As the burden of proof rested with the revenue, the tribunal found the valuation unsustainable and set aside the impugned order.
Undervaluation - Imports of high-end foreign cars - The appellate tribunal noted that the assessable value was determined using various sources, including the car manufacturer's website and internet values. However, crucial information, such as Alberto's retracted statement and documentary evidence, was not adequately considered. The tribunal observed discrepancies in the invoices and highlighted the lack of evidence supporting the revenue's allegations of under-valuation. As the burden of proof rested with the revenue, the tribunal found the valuation unsustainable and set aside the impugned order.
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