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...
Offence u/s 276C(2) - non payment of self-assessment tax along with the return of income - even though tax payment delayed and made after coercive steps were taken, it do not lead to the inference that it is an attempt to evade tax declared - it may call for imposition of penalty or interest, but by no stretch of imagination, it could be construed as an attempt to evade tax so as to entail prosecution u/s 276C(2)
Offence u/s 276C(2) - non payment of self-assessment tax along with the return of income - even though tax payment delayed and made after coercive steps were taken, it do not lead to the inference that it is an attempt to evade tax declared - it may call for imposition of penalty or interest, but by no stretch of imagination, it could be construed as an attempt to evade tax so as to entail prosecution u/s 276C(2)
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