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...
Violation of natural justice and entitlement to personal hearing is addressed in the context of writ jurisdiction and availability of statutory appellate remedy; where a statutory forum exists and is functional, the writ remedy should be relegated and the statutory appeal procedure followed, including compliance with any conditions attached to filing such appeal (pre-deposit requirement), and the writ court must not bypass those conditions. The petition was disposed directing availing of the appellate forum without expressing opinion on merits, and interlocutory applications stood disposed.
Violation of natural justice and entitlement to personal hearing is addressed in the context of writ jurisdiction and availability of statutory appellate remedy; where a statutory forum exists and is functional, the writ remedy should be relegated and the statutory appeal procedure followed, including compliance with any conditions attached to filing such appeal (pre-deposit requirement), and the writ court must not bypass those conditions. The petition was disposed directing availing of the appellate forum without expressing opinion on merits, and interlocutory applications stood disposed.
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