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...
Best Judgement Assessment - whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice u/s 143(2) for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of the Act and proceed directly u/s 144 by rejecting the return filed by the Assessee. - HC
Best Judgement Assessment - whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice u/s 143(2) for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of the Act and proceed directly u/s 144 by rejecting the return filed by the Assessee. - HC
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