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...
Revision u/s 263 by CIT - the AO despite having recorded that though the assessee trust’s activity fall under the ambit of “general public utility”, they are of commercial in nature and are covered by first and second proviso of section 2(15) - However, he erroneously assessed income of the assessee at Rs.NIL. - it is the clear case where the assessment order is erroneous and self-contradictory. - AT
Revision u/s 263 by CIT - the AO despite having recorded that though the assessee trust’s activity fall under the ambit of “general public utility”, they are of commercial in nature and are covered by first and second proviso of section 2(15) - However, he erroneously assessed income of the assessee at Rs.NIL. - it is the clear case where the assessment order is erroneous and self-contradictory. - AT
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