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...
Cancellation of registration u/s 12A was done retrospectively from 1.4.2014, despite show cause notice being issued on 6.10.2022 by CIT(E). CIT(E) failed to provide reasons for rejecting assessee's explanations. Order shows reasons for show cause notice were same as those considered by AO for assessment years 2013-14 and 2014-15. Provisions of sections 12AA/12AB do not permit retrospective cancellation of registration u/s 12A. Registration could earlier be cancelled u/s 12AB(5), but provisions of sections 12AA and 12AB came into effect from 1.4.2015. Statute does not provide power to cancel registration retrospectively. Assessee's appeal allowed.
Cancellation of registration u/s 12A was done retrospectively from 1.4.2014, despite show cause notice being issued on 6.10.2022 by CIT(E). CIT(E) failed to provide reasons for rejecting assessee's explanations. Order shows reasons for show cause notice were same as those considered by AO for assessment years 2013-14 and 2014-15. Provisions of sections 12AA/12AB do not permit retrospective cancellation of registration u/s 12A. Registration could earlier be cancelled u/s 12AB(5), but provisions of sections 12AA and 12AB came into effect from 1.4.2015. Statute does not provide power to cancel registration retrospectively. Assessee's appeal allowed.
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