Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Section 153C jurisdiction was upheld by the majority because...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verification.
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Section 153C jurisdiction was upheld by the majority because both Assessing Officers recorded satisfaction that seized material related to the assessee and affected income determination. No prescribed period governed satisfaction by the Assessing Officer of the other person, and assessment limitation ran from transfer of the seized material. Natural justice did not require supplying statements or permitting cross-examination because the addition rested on seized electronic records rather than witness statements. The seized Excel sheet was treated as corroborated evidence of unexplained investment in a jointly acquired bungalow, as its transaction particulars matched the registered sale deed. The addition remained sustained, subject to verification of the assessee's ownership share and proportionate adjustment.
Section 153C jurisdiction was upheld by the majority because both Assessing Officers recorded satisfaction that seized material related to the assessee and affected income determination. No prescribed period governed satisfaction by the Assessing Officer of the other person, and assessment limitation ran from transfer of the seized material. Natural justice did not require supplying statements or permitting cross-examination because the addition rested on seized electronic records rather than witness statements. The seized Excel sheet was treated as corroborated evidence of unexplained investment in a jointly acquired bungalow, as its transaction particulars matched the registered sale deed. The addition remained sustained, subject to verification of the assessee's ownership share and proportionate adjustment.
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