Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
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Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Section 54(8)(e) of the CGST Act excludes from fund credit any refundable amount that was not passed on by the taxpayer; because the respondent admitted passing the tax burden to consumers, that exception did not apply and the refund could not be paid to consumers under the provision. The High Court nevertheless accepted a taxpayer proposal to deposit the refunded sum into a designated account and seek tariff reductions to benefit consumers-a procedure not provided by Section 54 or its Rules, impracticable to implement and legally impermissible. The High Court order creating this judicially fashioned refund mechanism was set aside.
Section 54(8)(e) of the CGST Act excludes from fund credit any refundable amount that was not passed on by the taxpayer; because the respondent admitted passing the tax burden to consumers, that exception did not apply and the refund could not be paid to consumers under the provision. The High Court nevertheless accepted a taxpayer proposal to deposit the refunded sum into a designated account and seek tariff reductions to benefit consumers-a procedure not provided by Section 54 or its Rules, impracticable to implement and legally impermissible. The High Court order creating this judicially fashioned refund mechanism was set aside.
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