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...
Rejection of declared transaction value was challenged on the ground that reassessment relied on contemporaneous import prices without adequate disclosure or opportunity to the importer; CESTAT held that Rule 12 requires written intimation of grounds and a reasonable hearing before discarding transaction value. The authority's use of NIDB contemporaneous prices was not transparently explained as comparable to the imported goods and was not made available pre-hearing, depriving the importer of a chance to rebut. Result: reassessment set aside for failure to give cogent reasons and opportunity consistent with the Valuation Rules.
Rejection of declared transaction value was challenged on the ground that reassessment relied on contemporaneous import prices without adequate disclosure or opportunity to the importer; CESTAT held that Rule 12 requires written intimation of grounds and a reasonable hearing before discarding transaction value. The authority's use of NIDB contemporaneous prices was not transparently explained as comparable to the imported goods and was not made available pre-hearing, depriving the importer of a chance to rebut. Result: reassessment set aside for failure to give cogent reasons and opportunity consistent with the Valuation Rules.
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