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...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Validity of reopening of the case u/s. 147 - Reasons to believe - addition as unexplained cash credit u/s. 68 against sale of shares / investments along with share premium - The ITAT found that the reasons recorded for reopening were vague and lacked specificity, and the approval obtained was mechanical. Additionally, it concluded that the transactions in question were sales of shares held as investments, supported by evidence provided by the appellant. Consequently, the ITAT ruled in favor of the appellant, allowing the appeals and rejecting the additions made by the AO.
Validity of reopening of the case u/s. 147 - Reasons to believe - addition as unexplained cash credit u/s. 68 against sale of shares / investments along with share premium - The ITAT found that the reasons recorded for reopening were vague and lacked specificity, and the approval obtained was mechanical. Additionally, it concluded that the transactions in question were sales of shares held as investments, supported by evidence provided by the appellant. Consequently, the ITAT ruled in favor of the appellant, allowing the appeals and rejecting the additions made by the AO.
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