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 condoned the 2,455-day delay in instituting appeals to the CIT(A), holding that reasonable cause excused the delay and it was not deliberate nor beneficial to the assessee. The Tribunal restored the dispute to the file of the ld. Assessing Officer (TDS) for limited verification and directed deletion of any section 234E fees levied for defaults prior to 01.06.2015. Section 234E fees assessed for the period from 01.06.2015 until actual filing of the TDS return (15.05.2016) are to be sustained. The appeals are otherwise disposed of in accordance with these directions.
The ITAT condoned the 2,455-day delay in instituting appeals to the CIT(A), holding that reasonable cause excused the delay and it was not deliberate nor beneficial to the assessee. The Tribunal restored the dispute to the file of the ld. Assessing Officer (TDS) for limited verification and directed deletion of any section 234E fees levied for defaults prior to 01.06.2015. Section 234E fees assessed for the period from 01.06.2015 until actual filing of the TDS return (15.05.2016) are to be sustained. The appeals are otherwise disposed of in accordance with these directions.
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