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 of notice issued u/s 142(1) - Referring to the precedent set by the Supreme Court in Hindustan Steel Ltd. vs. State of Orissa, the Tribunal emphasized that penalties should not be levied if the conduct of the assessee is not contumacious. In this case, the Tribunal found no evidence of contumacious behavior on the part of the appellant.
Penalty u/s 271(1)(b) - non-compliance of notice issued u/s 142(1) - Referring to the precedent set by the Supreme Court in Hindustan Steel Ltd. vs. State of Orissa, the Tribunal emphasized that penalties should not be levied if the conduct of the assessee is not contumacious. In this case, the Tribunal found no evidence of contumacious behavior on the part of the appellant.
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