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 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant provisions of the Income Tax Act. It suggested a thorough examination of whether Section 153(C) should have been invoked instead of Sections 147 and 148, especially considering the circumstances of the case. The Court highlighted the importance of procedural fairness and the duty of the Assessing Officer to provide all necessary documents and material to the Assessee. It emphasized the need for compliance with procedural safeguards to ensure a fair assessment process.
Reopening of assessment u/s 147 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant provisions of the Income Tax Act. It suggested a thorough examination of whether Section 153(C) should have been invoked instead of Sections 147 and 148, especially considering the circumstances of the case. The Court highlighted the importance of procedural fairness and the duty of the Assessing Officer to provide all necessary documents and material to the Assessee. It emphasized the need for compliance with procedural safeguards to ensure a fair assessment process.
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