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...
Appellant's claim for exemption under 2009 Notification for 2008-2011 disallowed retrospectively as 2011 Notification amending exemption scope intended prospective application without express retrospectivity. Appellant not obliged to follow Rule 6(7B) option available to assessee, not Revenue. Profit on settlement part of taxable value upheld under amended 2011 Notification widening exemption scope. Profit on foreign exchange sale to EEFC account holders non-taxable being separate transactions without consideration flow. Appeal partly allowed by CESTAT.
Appellant's claim for exemption under 2009 Notification for 2008-2011 disallowed retrospectively as 2011 Notification amending exemption scope intended prospective application without express retrospectivity. Appellant not obliged to follow Rule 6(7B) option available to assessee, not Revenue. Profit on settlement part of taxable value upheld under amended 2011 Notification widening exemption scope. Profit on foreign exchange sale to EEFC account holders non-taxable being separate transactions without consideration flow. Appeal partly allowed by CESTAT.
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