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...
Presumption of service by post governed the appeal, with proof of delivery under the General Clauses Act treated as prima facie evidence; the burden rested on the assessee to rebut non-receipt. The tribunal applied the doctrine that one cannot take advantage of ones own mistake (commodum ex injuria sua nemo habere debet) in light of unchanged registered principal place of business and misleading affidavits, concluding evidentiary presumption stood unrebutted. The consequence was acceptance of service at the registered address and dismissal of the appeal.
Presumption of service by post governed the appeal, with proof of delivery under the General Clauses Act treated as prima facie evidence; the burden rested on the assessee to rebut non-receipt. The tribunal applied the doctrine that one cannot take advantage of ones own mistake (commodum ex injuria sua nemo habere debet) in light of unchanged registered principal place of business and misleading affidavits, concluding evidentiary presumption stood unrebutted. The consequence was acceptance of service at the registered address and dismissal of the appeal.
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