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 informant is entitled to a final or enhanced reward under the Guidelines for Grant of Rewards to Informants, 2007. Reasoning: Clause 15.1 authorizes an interim reward (Rs.100,000 already paid) and Clauses 2.1, 13.1-13.2 prescribe that a three-member Committee determine final quantum, including adjustments post-appeal; no Committee decision or reasoned order was placed on record. Outcome: respondents must have the prescribed Committee hear the informant and decide-either enhance the reward or confirm no further payment-by a reasoned order within six months. - HC
Dominant issue: whether informant is entitled to a final or enhanced reward under the Guidelines for Grant of Rewards to Informants, 2007. Reasoning: Clause 15.1 authorizes an interim reward (Rs.100,000 already paid) and Clauses 2.1, 13.1-13.2 prescribe that a three-member Committee determine final quantum, including adjustments post-appeal; no Committee decision or reasoned order was placed on record. Outcome: respondents must have the prescribed Committee hear the informant and decide-either enhance the reward or confirm no further payment-by a reasoned order within six months. - HC
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