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...
Penalty proceedings under s. 270A based on additions for delayed PF/ESI payments under s. 36(1)(va) were held vitiated for breach of natural justice, since no effective hearing was granted despite requests to keep the matter in abeyance pending appeal. The impugned penalty order was therefore quashed to the extent it related to those additions, and the matter was remitted for a fresh determination after affording a hearing, to be completed within 12 weeks. - HC
Penalty proceedings under s. 270A based on additions for delayed PF/ESI payments under s. 36(1)(va) were held vitiated for breach of natural justice, since no effective hearing was granted despite requests to keep the matter in abeyance pending appeal. The impugned penalty order was therefore quashed to the extent it related to those additions, and the matter was remitted for a fresh determination after affording a hearing, to be completed within 12 weeks. - HC
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