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...
Validity of reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons recorded did not mention forming reason to believe due to DVO report in co-owner's case - reliance on DVO report to justify reopening untenable as no fresh material part of recorded reasons - petitioner fully disclosed material facts during original assessment - change of opinion for reopening by impugned notice u/s 148 untenable - impugned notice unsustainable - assessee entitled to benefit enjoyed by co-owners whose valuation accepted - permitting impugned notice an exercise in futility - assessee appeal allowed.
Validity of reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons recorded did not mention forming reason to believe due to DVO report in co-owner's case - reliance on DVO report to justify reopening untenable as no fresh material part of recorded reasons - petitioner fully disclosed material facts during original assessment - change of opinion for reopening by impugned notice u/s 148 untenable - impugned notice unsustainable - assessee entitled to benefit enjoyed by co-owners whose valuation accepted - permitting impugned notice an exercise in futility - assessee appeal allowed.
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