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...
Revision jurisdiction was contested where revenue sought to revise an assessment by treating purchases as bogus. Tribunal found the assessing officer had issued statutory notices, conducted inquiries including notices to suppliers, and taken a plausible view after considering submissions; therefore the revisional officer could not substitute that view under the power to correct orders deemed "prejudicial to the interests of the revenue." Clauses in Explanation 2 relied on by the revisional officer were held unsupported by facts or law, the revisional order was set aside, and the appeal decided against the revenue.
Revision jurisdiction was contested where revenue sought to revise an assessment by treating purchases as bogus. Tribunal found the assessing officer had issued statutory notices, conducted inquiries including notices to suppliers, and taken a plausible view after considering submissions; therefore the revisional officer could not substitute that view under the power to correct orders deemed "prejudicial to the interests of the revenue." Clauses in Explanation 2 relied on by the revisional officer were held unsupported by facts or law, the revisional order was set aside, and the appeal decided against the revenue.
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