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...
Benami transaction - possession of a significant amount of cash - Validity of summoning order - The High Court found merit in the applicant's arguments, emphasizing the lack of sufficient grounds for prosecution under Section 53 of the PBPT Act. It noted the absence of allegations regarding the intention to defeat legal provisions or evade dues in the complaint, rendering the summoning order devoid of legal basis. Emphasizing the seriousness of summoning an accused, the Court granted interim relief, staying further proceedings pending full consideration of the matter.
Benami transaction - possession of a significant amount of cash - Validity of summoning order - The High Court found merit in the applicant's arguments, emphasizing the lack of sufficient grounds for prosecution under Section 53 of the PBPT Act. It noted the absence of allegations regarding the intention to defeat legal provisions or evade dues in the complaint, rendering the summoning order devoid of legal basis. Emphasizing the seriousness of summoning an accused, the Court granted interim relief, staying further proceedings pending full consideration of the matter.
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