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...
Reimbursement received not consideration for taxable service. CENVAT credit on debit notes containing requisite particulars admissible. CENVAT credit on invoices for out-of-pocket expenses allowed. Extended period of limitation unsustainable as no allegation of deliberate tax evasion. No interest payable on CENVAT credit availed but not utilized as credit reversed before utilization tantamount to non-availment. Appeal allowed by CESTAT.
Reimbursement received not consideration for taxable service. CENVAT credit on debit notes containing requisite particulars admissible. CENVAT credit on invoices for out-of-pocket expenses allowed. Extended period of limitation unsustainable as no allegation of deliberate tax evasion. No interest payable on CENVAT credit availed but not utilized as credit reversed before utilization tantamount to non-availment. Appeal allowed by CESTAT.
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