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...
Penalty u/s 158BFA(2) - period of limitation - relevant date - on the issue of additions, ITAT and HC decided the matter in favor of assessee whereas Supreme Court has finally decided the matter in favor of Revenue - The notice is well within six months from the date of the order of Hon'ble Supreme Court and therefore, it cannot be gainsaid that impugned order is barred by limitation - penalty upheld
Penalty u/s 158BFA(2) - period of limitation - relevant date - on the issue of additions, ITAT and HC decided the matter in favor of assessee whereas Supreme Court has finally decided the matter in favor of Revenue - The notice is well within six months from the date of the order of Hon'ble Supreme Court and therefore, it cannot be gainsaid that impugned order is barred by limitation - penalty upheld
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