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...
Role of AO as adjudicator in making the computation - Assessment made u/s 147 r.w.s. 144 and 144B - It is clear that the Parliament intended the AO to be both investigator, for purpose of detecting income having escaped assessment and adjudicator, for making the best judgment assessment. - AO abdicated his role as adjudicator in making the computation - Matter restored back - HC
Role of AO as adjudicator in making the computation - Assessment made u/s 147 r.w.s. 144 and 144B - It is clear that the Parliament intended the AO to be both investigator, for purpose of detecting income having escaped assessment and adjudicator, for making the best judgment assessment. - AO abdicated his role as adjudicator in making the computation - Matter restored back - HC
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