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 - Addition u/s 68 - unexplained deposits in bank account - assessee is a small time tea and pakoda seller and he could not have been expected to grasp intricacies of Income Tax Law - As reached the conclusion that the assessee’s case deserves that a sympathetic view may be taken - the assessment order was also passed exparte qua the assessee as the assessee had furnished the reply before the wrong AO. - AT
Reopening of assessment u/s 147 - Addition u/s 68 - unexplained deposits in bank account - assessee is a small time tea and pakoda seller and he could not have been expected to grasp intricacies of Income Tax Law - As reached the conclusion that the assessee’s case deserves that a sympathetic view may be taken - the assessment order was also passed exparte qua the assessee as the assessee had furnished the reply before the wrong AO. - AT
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