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 - Validity of notice issued u/s 148 and 148A(b) - the notice issued under Section 148A(b) of the Act should have clearly brought out the allegations against the petitioner. - Notice and orders are set aside, with liberty to the AO to issue a fresh notice u/s 148A(b) of the Act - HC
Reopening of assessment u/s 147 - Validity of notice issued u/s 148 and 148A(b) - the notice issued under Section 148A(b) of the Act should have clearly brought out the allegations against the petitioner. - Notice and orders are set aside, with liberty to the AO to issue a fresh notice u/s 148A(b) of the Act - HC
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