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...
HC held that under the unamended Section 3(12) of Customs Tariff Act, 1975, imposing interest, penalty, and redemption fine on IGST was without legal authority. Following the precedent in Mahindra & Mahindra Limited, the court quashed the impugned order levying interest and penalties. The amendment to Section 3(12) by Finance Act, 2024 is prospective, applicable only from 16th August, 2024. Additionally, a trade notice allowed regularization of imports under Advance Authorization Scheme that could not meet pre-import conditions, further supporting the court's decision to set aside confiscation and redemption fine. Petition allowed.
HC held that under the unamended Section 3(12) of Customs Tariff Act, 1975, imposing interest, penalty, and redemption fine on IGST was without legal authority. Following the precedent in Mahindra & Mahindra Limited, the court quashed the impugned order levying interest and penalties. The amendment to Section 3(12) by Finance Act, 2024 is prospective, applicable only from 16th August, 2024. Additionally, a trade notice allowed regularization of imports under Advance Authorization Scheme that could not meet pre-import conditions, further supporting the court's decision to set aside confiscation and redemption fine. Petition allowed.
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