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...
Validity of order passed by the Income Tax Settlement Commission [ITSC] u/s 245D(4) - proof of procedural error committed by the ITSC or any error with regard to the decision making process - full and true disclosure - learned Single Judge has set aside the order of ITSC - If a very rigid approach is taken in this regard, then the very purpose of enacting Sub-Section (6) of Section 245D of the Act would lose its purpose. In any event, we find that there is no error in the decision making process and as pointed out, we are not expected to substitute the decision of the ITSC, which has taken note of the conduct of the assessee, who was in the spirit of settlement subject to conditions - we are of the view that the order passed in the said writ petition calls for interference. - HC
Validity of order passed by the Income Tax Settlement Commission [ITSC] u/s 245D(4) - proof of procedural error committed by the ITSC or any error with regard to the decision making process - full and true disclosure - learned Single Judge has set aside the order of ITSC - If a very rigid approach is taken in this regard, then the very purpose of enacting Sub-Section (6) of Section 245D of the Act would lose its purpose. In any event, we find that there is no error in the decision making process and as pointed out, we are not expected to substitute the decision of the ITSC, which has taken note of the conduct of the assessee, who was in the spirit of settlement subject to conditions - we are of the view that the order passed in the said writ petition calls for interference. - HC
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