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...
Provisional attachment of properties held by company officials was sustained where they were found to have actively assisted directors in promoting unlawful preference-share schemes, mobilising public investments and diverting proceeds of the scheduled offence. Recorded statements and charge-sheet material linked the officials to the acquisition of properties in their names. Their claim that the properties were purchased solely from salary and incentives was rejected because the attached value was substantially lower than amounts received from the company. The attachment remains subject to the final outcome of the criminal proceedings.
Provisional attachment of properties held by company officials was sustained where they were found to have actively assisted directors in promoting unlawful preference-share schemes, mobilising public investments and diverting proceeds of the scheduled offence. Recorded statements and charge-sheet material linked the officials to the acquisition of properties in their names. Their claim that the properties were purchased solely from salary and incentives was rejected because the attached value was substantially lower than amounts received from the company. The attachment remains subject to the final outcome of the criminal proceedings.
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