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...
Validity of order passed u/s 143(3) r.w.s. 92CA without passing draft order of assessment - eligibility of assessee - once TPO passed order u/s 92CA, assessee is an “eligible assessee” and the issuance of a draft order of assessment is a sine-qua-non before the AO can pass the regular / final order of assessment u/s 143(3) r.w.s. 144C - mandatory requirement under law, cannot be termed as a mere procedural irregularity and is not curable
Validity of order passed u/s 143(3) r.w.s. 92CA without passing draft order of assessment - eligibility of assessee - once TPO passed order u/s 92CA, assessee is an “eligible assessee” and the issuance of a draft order of assessment is a sine-qua-non before the AO can pass the regular / final order of assessment u/s 143(3) r.w.s. 144C - mandatory requirement under law, cannot be termed as a mere procedural irregularity and is not curable
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