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...
Assessment u/s 144C - Reply submitted by the assessee is not considered while passing the assessment order at Ext.P7 rather it is noted therein that petitioner did not respond to the show cause notice at Ext.P4. - At this stage, it is not possible to accept the contention of the learned Standing Counsel appearing for the respondent (Revenue) that there was no need of issuance of show cause notice at Ext.P4, particularly, when the respondent had chosen to issue the said show cause notice at Ext.P4 to the petitioner. The impugned order therefore prima facie suffers from the perversity as well as non-compliance with the principles of natural justice. - HC
Assessment u/s 144C - Reply submitted by the assessee is not considered while passing the assessment order at Ext.P7 rather it is noted therein that petitioner did not respond to the show cause notice at Ext.P4. - At this stage, it is not possible to accept the contention of the learned Standing Counsel appearing for the respondent (Revenue) that there was no need of issuance of show cause notice at Ext.P4, particularly, when the respondent had chosen to issue the said show cause notice at Ext.P4 to the petitioner. The impugned order therefore prima facie suffers from the perversity as well as non-compliance with the principles of natural justice. - HC
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