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...
Determination of export duty hinges on validity of re-test results and reliance on laboratory reports; the tribunal accepted that a subsequent re-test produced lower Fe content (55.6%) and noted discharge port sampling at 57.2% upon which transaction value was based, concluding lower authorities properly examined factual evidence and testing competence and need not be disturbed. The decision upholds reliance on the competent laboratory re-test over earlier reports, confirms acceptance of invoice value tied to discharge port Fe content, and dismisses the revenue appeal, leaving the provisional assessment and final factual findings intact.
Determination of export duty hinges on validity of re-test results and reliance on laboratory reports; the tribunal accepted that a subsequent re-test produced lower Fe content (55.6%) and noted discharge port sampling at 57.2% upon which transaction value was based, concluding lower authorities properly examined factual evidence and testing competence and need not be disturbed. The decision upholds reliance on the competent laboratory re-test over earlier reports, confirms acceptance of invoice value tied to discharge port Fe content, and dismisses the revenue appeal, leaving the provisional assessment and final factual findings intact.
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