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...
Reassessment Notice u/s 148 - even assuming that at the time notice was issued the Respondent was not fully aware of all the relevant facts, once the Petitioner submitted its objections drawing his attention to the specific legal position, it was obligatory for the AO to have applied his mind to those points - the fundamental premise that the investment in the shares of its subsidiary amounted to ‘income’ which had escaped assessment was flawed - notice quashed
Reassessment Notice u/s 148 - even assuming that at the time notice was issued the Respondent was not fully aware of all the relevant facts, once the Petitioner submitted its objections drawing his attention to the specific legal position, it was obligatory for the AO to have applied his mind to those points - the fundamental premise that the investment in the shares of its subsidiary amounted to ‘income’ which had escaped assessment was flawed - notice quashed
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