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...
Transfer of case u/s 127 - in the impugned order, the Pr. CIT has relied on various statements of the assessees of the said group, on the basis of which he came to the conclusion that it would be necessary to centralize - none of these aspects were stated in the sCN means no opportunity to meet with such adverse material which the Pr. CIT pressed in service for passing the impugned order - order is quashed
Transfer of case u/s 127 - in the impugned order, the Pr. CIT has relied on various statements of the assessees of the said group, on the basis of which he came to the conclusion that it would be necessary to centralize - none of these aspects were stated in the sCN means no opportunity to meet with such adverse material which the Pr. CIT pressed in service for passing the impugned order - order is quashed
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