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 - Period of limitation - The audit party is entitled to point out a factual error or omission in the assessment. reopening of the assessment in the light of factual errors pointed out by the audit party is permissible under law. In the present case, even though the assessment was reopened on the basis of the error pointed out by the revenue audit, the same was done after the period prescribed u/s 147. Tribunal is right in allowing the appeal filed by the assessee. - HC
Reopening of assessment u/s 147 - Period of limitation - The audit party is entitled to point out a factual error or omission in the assessment. reopening of the assessment in the light of factual errors pointed out by the audit party is permissible under law. In the present case, even though the assessment was reopened on the basis of the error pointed out by the revenue audit, the same was done after the period prescribed u/s 147. Tribunal is right in allowing the appeal filed by the assessee. - HC
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