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...
Validity of Reopening of assessment - The mere submission of books of accounts and the certificate issued by the Statutory Auditor would not amount to the fact that the petitioner has disclosed fully and truly all material facts - The reasons recorded by the Principal Commissioner of Income Tax to accord sanction for the issue of notice u/s 148 cannot be said that the sanction was granted mechanically and without application of the mind. - HC
Validity of Reopening of assessment - The mere submission of books of accounts and the certificate issued by the Statutory Auditor would not amount to the fact that the petitioner has disclosed fully and truly all material facts - The reasons recorded by the Principal Commissioner of Income Tax to accord sanction for the issue of notice u/s 148 cannot be said that the sanction was granted mechanically and without application of the mind. - HC
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