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...
Cancellation of GST registration was held vitiated for breach of natural justice where the taxpayer's revocation application remained undecided beyond the statutory time and the department failed to disclose its status, undermining the cancellation process; consequently, the show-cause notice, cancellation order, and appellate dismissal were set aside. Further, the department's stance was internally inconsistent: cancellation proceeded on the premise of no business activity at the premises, yet best-judgment assessments under section 63 for multiple prior years alleged continued business based on GSTR-2A; this contradiction rendered the impugned cancellation-related actions unsustainable. The separate section 63 assessment orders were left to be challenged through statutory appeals. - HC
Cancellation of GST registration was held vitiated for breach of natural justice where the taxpayer's revocation application remained undecided beyond the statutory time and the department failed to disclose its status, undermining the cancellation process; consequently, the show-cause notice, cancellation order, and appellate dismissal were set aside. Further, the department's stance was internally inconsistent: cancellation proceeded on the premise of no business activity at the premises, yet best-judgment assessments under section 63 for multiple prior years alleged continued business based on GSTR-2A; this contradiction rendered the impugned cancellation-related actions unsustainable. The separate section 63 assessment orders were left to be challenged through statutory appeals. - HC
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