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...
Assessment u/s 153A - notice u/s 143 (2) - A specific notice is required to be issued u/s 153A(1)(a) calling upon the persons searched or requisitioned to file return - That being so, no further notices u/s 143(2) can be contemplated for assessment u/s 153A - The words 'so far as may be' in Section 153A(1)(a)cannot be interpreted that the issue of notice u/s 143(2) is mandatory
Assessment u/s 153A - notice u/s 143 (2) - A specific notice is required to be issued u/s 153A(1)(a) calling upon the persons searched or requisitioned to file return - That being so, no further notices u/s 143(2) can be contemplated for assessment u/s 153A - The words 'so far as may be' in Section 153A(1)(a)cannot be interpreted that the issue of notice u/s 143(2) is mandatory
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