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...
Commissioner failed to follow binding Tribunal precedents on classification of bio-fungicides and bio-insecticides, erroneously believing Supreme Court appeals left issue open. Tribunal clarified Supreme Court appeals were on different issues, not classification. Commissioner bound by Tribunal precedents, cannot independently decide contrary. Order set aside for not following judicial discipline and binding precedents, displaying mala fides. Appeal allowed.
Commissioner failed to follow binding Tribunal precedents on classification of bio-fungicides and bio-insecticides, erroneously believing Supreme Court appeals left issue open. Tribunal clarified Supreme Court appeals were on different issues, not classification. Commissioner bound by Tribunal precedents, cannot independently decide contrary. Order set aside for not following judicial discipline and binding precedents, displaying mala fides. Appeal allowed.
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