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...
The ITAT held that the approval granted under section 153D was invalid as the Approving Authority failed to independently examine the assessment records or seized materials before granting consolidated approval. The approval was based solely on the draft assessment order without any application of mind, rendering it a mechanical and perfunctory act. Consequently, the approval did not comply with the statutory requirements under section 153D. The tribunal set aside the approval, holding it to be void ab initio, and allowed the assessee's appeal.
The ITAT held that the approval granted under section 153D was invalid as the Approving Authority failed to independently examine the assessment records or seized materials before granting consolidated approval. The approval was based solely on the draft assessment order without any application of mind, rendering it a mechanical and perfunctory act. Consequently, the approval did not comply with the statutory requirements under section 153D. The tribunal set aside the approval, holding it to be void ab initio, and allowed the assessee's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
