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...
Revision u/s 263 by CIT - Even after giving effect to the order of the ld. PCIT u/s.263 of the Act, there would be no taxable income under normal provisions of the Act and even then, the income would ultimately get determined only u/s.115JB of the Act. Hence, there would be no prejudice that could be caused to the interest of the Revenue in this regard. - AT
Revision u/s 263 by CIT - Even after giving effect to the order of the ld. PCIT u/s.263 of the Act, there would be no taxable income under normal provisions of the Act and even then, the income would ultimately get determined only u/s.115JB of the Act. Hence, there would be no prejudice that could be caused to the interest of the Revenue in this regard. - AT
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