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...
Penalty u/s 271(1)(c) - revision u/s 263 - In the absence of any finding of the AO with regard to concealment of income or with regard to furnishing of inaccurate particulars of income, the CIT clearly erred in holding that omission to record satisfaction to initiate penalty proceedings was erroneous or prejudicial to the interest of Revenue. - HC
Penalty u/s 271(1)(c) - revision u/s 263 - In the absence of any finding of the AO with regard to concealment of income or with regard to furnishing of inaccurate particulars of income, the CIT clearly erred in holding that omission to record satisfaction to initiate penalty proceedings was erroneous or prejudicial to the interest of Revenue. - HC
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