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...
Entitlement to interest on the delayed refund of pre-deposit - Rate of interest - seizure of cash - The court ruled in favor of the appellant, emphasizing that judicial precedents supported a 12% interest rate in the absence of specific statutory provisions at the relevant time. The court rejected the respondents' argument that the interest rate should be 6% based on later notifications, as these were not applicable to the period in question.
Entitlement to interest on the delayed refund of pre-deposit - Rate of interest - seizure of cash - The court ruled in favor of the appellant, emphasizing that judicial precedents supported a 12% interest rate in the absence of specific statutory provisions at the relevant time. The court rejected the respondents' argument that the interest rate should be 6% based on later notifications, as these were not applicable to the period in question.
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