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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
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Validity of assessment order passed u/s 153C - Third Member Order - addition u/s 69A r.w.s. 115BBE - cash deposited in various bank accounts post demonetization - search and seizure operation carried out in case of Third Party - The tribunal concluded that the assessment order under section 143(3) read with section 153C was invalid. This conclusion was primarily based on the procedural impropriety in the issuance of the assessment order without proper compliance with the prerequisites outlined in section 153C, notably the recording of satisfaction. - Regarding the Cash Deposit, the tribunal underscored the importance of drawing statutory presumptions against the entity in whose name the deposits were made, rather than the assessee, in the absence of incontrovertible proof to the contrary.
Validity of assessment order passed u/s 153C - Third Member Order - addition u/s 69A r.w.s. 115BBE - cash deposited in various bank accounts post demonetization - search and seizure operation carried out in case of Third Party - The tribunal concluded that the assessment order under section 143(3) read with section 153C was invalid. This conclusion was primarily based on the procedural impropriety in the issuance of the assessment order without proper compliance with the prerequisites outlined in section 153C, notably the recording of satisfaction. - Regarding the Cash Deposit, the tribunal underscored the importance of drawing statutory presumptions against the entity in whose name the deposits were made, rather than the assessee, in the absence of incontrovertible proof to the contrary.
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