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...
Issue concerns smuggling allegations of gold, applicability of statutory specified area designation, and the burden of proof on revenue to establish foreign origin. The tribunal found absence of foreign markings, recovery outside customs or specified areas, and documentary records of lawful possession including tax returns and auditor certificate, which were not impugned by the revenue; on that evidentiary basis the revenue failed to produce positive evidence of foreign origin. The analysis addressed provisional release, seizure and confiscation of conveyance and accessories, and comparative purity as factual indicators of origin.
Issue concerns smuggling allegations of gold, applicability of statutory specified area designation, and the burden of proof on revenue to establish foreign origin. The tribunal found absence of foreign markings, recovery outside customs or specified areas, and documentary records of lawful possession including tax returns and auditor certificate, which were not impugned by the revenue; on that evidentiary basis the revenue failed to produce positive evidence of foreign origin. The analysis addressed provisional release, seizure and confiscation of conveyance and accessories, and comparative purity as factual indicators of origin.
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