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...
Re-assessment u/s 147 - no failure on the part of the assessee to disclose all the relevant facts truly and fully for assessment - AO cannot have a mere re-appreciation of the same facts or a review of existing material on a mere change of opinion and take a different view of the matter - limitation of 4 years is a protection of whimsical and arbitrary re-assessment proceedings
Re-assessment u/s 147 - no failure on the part of the assessee to disclose all the relevant facts truly and fully for assessment - AO cannot have a mere re-appreciation of the same facts or a review of existing material on a mere change of opinion and take a different view of the matter - limitation of 4 years is a protection of whimsical and arbitrary re-assessment proceedings
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