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...
Reopening of assessment u/s 147 - Scope of new regime of Section 148A - The principle of law, as explained by the Supreme Court, in the case of GKN Driveshaft (India) Ltd [2002 (11) TMI 7 - SUPREME COURT], is now a statutory provision in the form of new Section 148A of the Act. - We are of the view that we should quash and set aside the order passed under clause (d) of Section 148A as well as the notice issued under Section 148 of the Act, 1961 and remit the matter to the Assessing Officer for fresh consideration of the objections filed by the writ applicant. - HC
Reopening of assessment u/s 147 - Scope of new regime of Section 148A - The principle of law, as explained by the Supreme Court, in the case of GKN Driveshaft (India) Ltd [2002 (11) TMI 7 - SUPREME COURT], is now a statutory provision in the form of new Section 148A of the Act. - We are of the view that we should quash and set aside the order passed under clause (d) of Section 148A as well as the notice issued under Section 148 of the Act, 1961 and remit the matter to the Assessing Officer for fresh consideration of the objections filed by the writ applicant. - HC
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