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 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to the subject matter of re-assessment, the limitation would start from the date of Re-assessment Order. However, if the subject matter of the re-assessment is distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers u/s 263 would be the date of the original Assessment Order. - SC
Revision u/s 263 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to the subject matter of re-assessment, the limitation would start from the date of Re-assessment Order. However, if the subject matter of the re-assessment is distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers u/s 263 would be the date of the original Assessment Order. - SC
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