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...
ITAT held the assessment order invalid for non-compliance with the mandatory procedure under Section 144C. The AO passed the final assessment order before expiry of the 30-day period prescribed in Section 144C(2) for the assessee to file objections to the draft assessment order, thereby frustrating the assessee's statutory right to approach the DRP. ITAT ruled that such breach rendered the final assessment order unsustainable in law. The final assessment order passed under Section 144C was quashed, and all additions, disallowances and the consequential tax demand raised on the assessee were deleted.
ITAT held the assessment order invalid for non-compliance with the mandatory procedure under Section 144C. The AO passed the final assessment order before expiry of the 30-day period prescribed in Section 144C(2) for the assessee to file objections to the draft assessment order, thereby frustrating the assessee's statutory right to approach the DRP. ITAT ruled that such breach rendered the final assessment order unsustainable in law. The final assessment order passed under Section 144C was quashed, and all additions, disallowances and the consequential tax demand raised on the assessee were deleted.
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