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...
Faceless Assessment - Non affording a reasonable opportunity to be heard through video conferencing - The court referred to Section 144B(6)(vii) and (viii) of the Income Tax Act, which mandates that where a request for a personal hearing is made, it must be provided, and the hearing shall be conducted through video conferencing. The court noted that since the petitioner had requested a video conferencing hearing, it was mandatory for the respondent to accede to the request. The court emphasized the importance of affording the assessee a reasonable opportunity of being heard before passing an adverse order, citing it as a fundamental principle of natural justice. - Consequently, the court set aside the assessment order and remanded the matter to the concerned Assessing Officer for reconsideration.
Faceless Assessment - Non affording a reasonable opportunity to be heard through video conferencing - The court referred to Section 144B(6)(vii) and (viii) of the Income Tax Act, which mandates that where a request for a personal hearing is made, it must be provided, and the hearing shall be conducted through video conferencing. The court noted that since the petitioner had requested a video conferencing hearing, it was mandatory for the respondent to accede to the request. The court emphasized the importance of affording the assessee a reasonable opportunity of being heard before passing an adverse order, citing it as a fundamental principle of natural justice. - Consequently, the court set aside the assessment order and remanded the matter to the concerned Assessing Officer for reconsideration.
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