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...
Whether an assessee may file an updated return under Section 139(8A) once assessment proceedings are pending: the court interpreted clause (b) of the third proviso to s.139(8A) to allow no updated return for the relevant year where assessment/reassessment/recomputation or revision proceedings are pending or completed; therefore the AO correctly refused the updated ITR request after initiation of s.143(2)/assessment u/s 143(3) r/w s.144B and proceeded to disallow exemptions and deductions on merits - request rejected and assessment sustained; appellate remedy preserved. - HC
Whether an assessee may file an updated return under Section 139(8A) once assessment proceedings are pending: the court interpreted clause (b) of the third proviso to s.139(8A) to allow no updated return for the relevant year where assessment/reassessment/recomputation or revision proceedings are pending or completed; therefore the AO correctly refused the updated ITR request after initiation of s.143(2)/assessment u/s 143(3) r/w s.144B and proceeded to disallow exemptions and deductions on merits - request rejected and assessment sustained; appellate remedy preserved. - HC
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