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 dispute concerns de-bonding of a 100% Export Oriented Unit and application of Condition 10 of the Standard Conditions to determine final date of exit; the suo-motu de-bonding order dated 08.08.2006 was clarified as the final exit date and that factual finding must be considered. The appellate authority is obligated to conduct a de-novo enquiry and apply independent judicial mind rather than mechanically affirm prior findings; previous orders that refused fresh consideration and which the tribunal dismissed without reasons are unsustainable. The matter is remanded to the Commissioner (Appeals) for fresh, reasoned adjudication in accordance with law.
The dispute concerns de-bonding of a 100% Export Oriented Unit and application of Condition 10 of the Standard Conditions to determine final date of exit; the suo-motu de-bonding order dated 08.08.2006 was clarified as the final exit date and that factual finding must be considered. The appellate authority is obligated to conduct a de-novo enquiry and apply independent judicial mind rather than mechanically affirm prior findings; previous orders that refused fresh consideration and which the tribunal dismissed without reasons are unsustainable. The matter is remanded to the Commissioner (Appeals) for fresh, reasoned adjudication in accordance with law.
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