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...
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
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