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 Order passed u/s 73 - cryptic order - The High Court found merit in the petitioner's arguments regarding the inadequacy of the impugned order. It observed that the proper officer had failed to consider the detailed replies furnished by the petitioner, instead issuing a generic finding of no proper reply/explanation. The Court emphasized that the proper officer's duty was to assess the replies on their merit before forming an opinion. By neglecting to do so, the officer had not fulfilled this obligation and had not applied their mind to the petitioner's submissions. The matter was remitted to the proper officer for re-adjudication.
Validity Of Order passed u/s 73 - cryptic order - The High Court found merit in the petitioner's arguments regarding the inadequacy of the impugned order. It observed that the proper officer had failed to consider the detailed replies furnished by the petitioner, instead issuing a generic finding of no proper reply/explanation. The Court emphasized that the proper officer's duty was to assess the replies on their merit before forming an opinion. By neglecting to do so, the officer had not fulfilled this obligation and had not applied their mind to the petitioner's submissions. The matter was remitted to the proper officer for re-adjudication.
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