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...
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
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