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...
Dividend distribution tax was treated as a charge on the distributed profits of the domestic company, not as tax on the non-resident shareholder's income for DTAA purposes, so the India-Netherlands treaty did not support the refund claim. The Tribunal also held that the refund application was not maintainable because no return of income had been filed in accordance with the statutory refund procedure. On both grounds, the assessee's appeals were dismissed.
Dividend distribution tax was treated as a charge on the distributed profits of the domestic company, not as tax on the non-resident shareholder's income for DTAA purposes, so the India-Netherlands treaty did not support the refund claim. The Tribunal also held that the refund application was not maintainable because no return of income had been filed in accordance with the statutory refund procedure. On both grounds, the assessee's appeals were dismissed.
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