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...
The text addresses whether commission receipts relating to alleged sale/export of Indian raw cotton qualify as a non-taxable transfer of immovable property or as taxable services and whether exemption under Notification No.13/2003-ST applies; the documents were held insufficient to prove commission receipts as genuine sales commissions, resulting in denial of exemption. It also examines invocation of the extended assessment period due to undisclosed commission income and audit-detected mismatches, finding suppression with intent to evade service tax and upholding extended-period assessment and confirmed service tax demand for 2010-11 and 2011-12.
The text addresses whether commission receipts relating to alleged sale/export of Indian raw cotton qualify as a non-taxable transfer of immovable property or as taxable services and whether exemption under Notification No.13/2003-ST applies; the documents were held insufficient to prove commission receipts as genuine sales commissions, resulting in denial of exemption. It also examines invocation of the extended assessment period due to undisclosed commission income and audit-detected mismatches, finding suppression with intent to evade service tax and upholding extended-period assessment and confirmed service tax demand for 2010-11 and 2011-12.
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