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...
Service tax liability on tour operators providing services within taxable territory of India, even if tours involve non-taxable territory - Planning, scheduling, organizing activities undertaken in taxable territory attract service tax - No intent to evade duty as interpretation of 'tour operator' contested - Extended period of limitation not invokable - Matter remanded to determine duty liability within normal limitation period.
Service tax liability on tour operators providing services within taxable territory of India, even if tours involve non-taxable territory - Planning, scheduling, organizing activities undertaken in taxable territory attract service tax - No intent to evade duty as interpretation of 'tour operator' contested - Extended period of limitation not invokable - Matter remanded to determine duty liability within normal limitation period.
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