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 a reassessment notice under s.148 could be issued by a jurisdictional AO despite s.151A and the notified faceless regime mandating issuance only by the designated faceless authority. Relying on a co-ordinate bench decision holding that such notices issued by an AO lacked jurisdiction in view of s.151A and the applicable notification, the impugned s.148 notice and consequential assessment orders were set aside. The pending appellate proceedings were directed to be closed with liberty to either side to seek revival/restoration if circumstances so require. - HC
The dominant issue was whether a reassessment notice under s.148 could be issued by a jurisdictional AO despite s.151A and the notified faceless regime mandating issuance only by the designated faceless authority. Relying on a co-ordinate bench decision holding that such notices issued by an AO lacked jurisdiction in view of s.151A and the applicable notification, the impugned s.148 notice and consequential assessment orders were set aside. The pending appellate proceedings were directed to be closed with liberty to either side to seek revival/restoration if circumstances so require. - HC
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