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...
Stay of Recovery proceedings - Prayer quashing 226(3) notice - The prayer sought for by the petitioner, for a certiorarified mandamus quashing 226(3) notice, is thus not liable to be granted. Had an application for stay been filed, one could have considered the disposal of that application pending appeal. However, that has also not been done. Thus, the petitioner, at this juncture, can only be permitted to seek appropriate interim protection from the appellate/administrative authorities, pending appeal. - HC
Stay of Recovery proceedings - Prayer quashing 226(3) notice - The prayer sought for by the petitioner, for a certiorarified mandamus quashing 226(3) notice, is thus not liable to be granted. Had an application for stay been filed, one could have considered the disposal of that application pending appeal. However, that has also not been done. Thus, the petitioner, at this juncture, can only be permitted to seek appropriate interim protection from the appellate/administrative authorities, pending appeal. - HC
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