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...
Faceless Assessment Unit failed to offer personal hearing opportunity through video conferencing despite petitioner's request as mandated u/s 144B(6)(viii). Petitioner's request approved but no video link shared. Mere creation of meeting ID/link without sharing insufficient to discharge statutory obligation. Faceless Assessment Unit's finding that petitioner chose not to attend video conference perverse, based on no evidence. Order dated 29th March 2024 vitiated for not affording personal hearing, set aside. Matter remanded to Faceless Assessment Unit with directions.
Faceless Assessment Unit failed to offer personal hearing opportunity through video conferencing despite petitioner's request as mandated u/s 144B(6)(viii). Petitioner's request approved but no video link shared. Mere creation of meeting ID/link without sharing insufficient to discharge statutory obligation. Faceless Assessment Unit's finding that petitioner chose not to attend video conference perverse, based on no evidence. Order dated 29th March 2024 vitiated for not affording personal hearing, set aside. Matter remanded to Faceless Assessment Unit with directions.
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