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 dominant issue was whether recovery of outstanding tax demand should be stayed under s. 220(6) while the assessee's stay application remained pending. The court held that no mandatory stay could be directed because the assessee's appeal before the ITAT had not yet been restored and the assessee had itself proposed payment of the demand in installments, undermining the basis for compelling a stay; accordingly, stay was refused. The Revenue was directed to decide the assessee's pending stay application under s. 156 expeditiously, preferably within four weeks, without treating the order as any mandate to grant stay. - HC
The dominant issue was whether recovery of outstanding tax demand should be stayed under s. 220(6) while the assessee's stay application remained pending. The court held that no mandatory stay could be directed because the assessee's appeal before the ITAT had not yet been restored and the assessee had itself proposed payment of the demand in installments, undermining the basis for compelling a stay; accordingly, stay was refused. The Revenue was directed to decide the assessee's pending stay application under s. 156 expeditiously, preferably within four weeks, without treating the order as any mandate to grant stay. - HC
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