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...
Penalty u/s 271(1)(b) - Non-compliance with a notice issued u/s 142(1) - The Tribunal noted that in a previous round of proceedings, a penalty under section 271(1)(b) of the Act had been deleted by the Tribunal, indicating a precedent in favor of the appellant. Considering the circumstances, including the quashing of the assessment order by the High Court in the second round of proceedings, the Tribunal found that the penalty imposed in connection with those proceedings was untenable.
Penalty u/s 271(1)(b) - Non-compliance with a notice issued u/s 142(1) - The Tribunal noted that in a previous round of proceedings, a penalty under section 271(1)(b) of the Act had been deleted by the Tribunal, indicating a precedent in favor of the appellant. Considering the circumstances, including the quashing of the assessment order by the High Court in the second round of proceedings, the Tribunal found that the penalty imposed in connection with those proceedings was untenable.
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