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...
Eligibility to avail the SVLDR Scheme for a second show cause notice issued after the Scheme's prescribed cut-off date was the dominant issue. The Court held that mere cross-reference to an earlier notice, or reliance on documents from it, does not render the later notice a continuation of the earlier proceedings; the later notice was an independent demand with separate quantification and adjudication. Since notices issued beyond the Scheme deadline are ineligible, rejection of the Scheme application for the later notice was upheld. However, to avoid denial of statutory remedies due to pendency of the writ, the petitioner was permitted to file an appeal against the adjudication order within the extended time granted. - HC
Eligibility to avail the SVLDR Scheme for a second show cause notice issued after the Scheme's prescribed cut-off date was the dominant issue. The Court held that mere cross-reference to an earlier notice, or reliance on documents from it, does not render the later notice a continuation of the earlier proceedings; the later notice was an independent demand with separate quantification and adjudication. Since notices issued beyond the Scheme deadline are ineligible, rejection of the Scheme application for the later notice was upheld. However, to avoid denial of statutory remedies due to pendency of the writ, the petitioner was permitted to file an appeal against the adjudication order within the extended time granted. - HC
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