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...
Removal of adverse remarks made against the Officer / counsel of the appellant - court not only give opportunity of explaining or defending the Officer / counsel but also decide that there is evidence on record bearing on that conduct justifying the remarks as well as it is necessary for the decision of the case, as an integral part thereof, to animadvert on that conduct - failing these test no adverse comment desirable
Removal of adverse remarks made against the Officer / counsel of the appellant - court not only give opportunity of explaining or defending the Officer / counsel but also decide that there is evidence on record bearing on that conduct justifying the remarks as well as it is necessary for the decision of the case, as an integral part thereof, to animadvert on that conduct - failing these test no adverse comment desirable
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