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...
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
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