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...
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
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