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...
Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.
Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
