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 - the AO has not made any enquiry and accepted the return of income filed by the assessee, as it is, without enquiring about the issue raised by the PCIT. - Whatever return of income filed by the assessee has been accepted by AO, blindly and without conducting any enquiry, hence order passed by the AO is erroneous as well as prejudicial to the interest of Revenue. - AT
Revision u/s 263 - the AO has not made any enquiry and accepted the return of income filed by the assessee, as it is, without enquiring about the issue raised by the PCIT. - Whatever return of income filed by the assessee has been accepted by AO, blindly and without conducting any enquiry, hence order passed by the AO is erroneous as well as prejudicial to the interest of Revenue. - AT
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