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...
Dominant issue: Whether statutory service under Section 153 was effected. The tribunal found documentary proof that orders and detention notices were returned undelivered and thereafter displayed on the Customs House notice board, satisfying the service mandate; therefore service was effective and the challenge on that ground fails. Substantive determination: Appellant's change of address, failure to notify revenue, and instructions to return postal communications evidenced lack of bona fides, supporting rejection of declared value and re-determination under Rule 9; appeals are dismissed and impugned orders upheld. - CESTAT
Dominant issue: Whether statutory service under Section 153 was effected. The tribunal found documentary proof that orders and detention notices were returned undelivered and thereafter displayed on the Customs House notice board, satisfying the service mandate; therefore service was effective and the challenge on that ground fails. Substantive determination: Appellant's change of address, failure to notify revenue, and instructions to return postal communications evidenced lack of bona fides, supporting rejection of declared value and re-determination under Rule 9; appeals are dismissed and impugned orders upheld. - CESTAT
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