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...
Application for rectification is confined to errors apparent on the record; re appreciation of evidence or revisiting factual findings is impermissible, and the rectification plea was dismissed. Penalty assessment principle confirmed: penalty must not exceed the demand upheld on remand, and Section 78 liability is to be re determined equal to the confirmed demand. Contract interpretation finding that the work order price expressly included service tax is a factual conclusion supported by contract terms and is not a patent error subject to rectification; that ground was rejected.
Application for rectification is confined to errors apparent on the record; re appreciation of evidence or revisiting factual findings is impermissible, and the rectification plea was dismissed. Penalty assessment principle confirmed: penalty must not exceed the demand upheld on remand, and Section 78 liability is to be re determined equal to the confirmed demand. Contract interpretation finding that the work order price expressly included service tax is a factual conclusion supported by contract terms and is not a patent error subject to rectification; that ground was rejected.
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