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...
A deficiency memo issued in Form GST RFD-03 under Rule 90(3) rejecting a refund claim on the ground that no GST Council notification/circular existed on refund relating to GST paid on transfer of assignment rights was challenged. The Court held that such a ground could not sustain rejection at the deficiency memo stage and the refund application was required to be processed in accordance with law. Consequently, the deficiency memo was quashed, the refund application was revived, and the authorities were directed to pass a reasoned order on the refund claim within three weeks of receipt of the revived application. - HC
A deficiency memo issued in Form GST RFD-03 under Rule 90(3) rejecting a refund claim on the ground that no GST Council notification/circular existed on refund relating to GST paid on transfer of assignment rights was challenged. The Court held that such a ground could not sustain rejection at the deficiency memo stage and the refund application was required to be processed in accordance with law. Consequently, the deficiency memo was quashed, the refund application was revived, and the authorities were directed to pass a reasoned order on the refund claim within three weeks of receipt of the revived application. - HC
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