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...
In a limited scrutiny selected only to examine share premium, the AO made an addition u/s 68 for unexplained cash credit relating to share application money, thereby travelling beyond the permitted scope; the addition and consequential assessment were held unsustainable and the assessment was quashed as nullity. Separately, the statutory notice u/s 143(2) was issued by one jurisdictional officer, but the assessment was completed by a different officer without a valid notice foundation; the assessment was held without jurisdiction and void ab initio, and was quashed. - ITAT
In a limited scrutiny selected only to examine share premium, the AO made an addition u/s 68 for unexplained cash credit relating to share application money, thereby travelling beyond the permitted scope; the addition and consequential assessment were held unsustainable and the assessment was quashed as nullity. Separately, the statutory notice u/s 143(2) was issued by one jurisdictional officer, but the assessment was completed by a different officer without a valid notice foundation; the assessment was held without jurisdiction and void ab initio, and was quashed. - ITAT
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