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...
Natural justice and audi alteram partem obligations govern appellate adjudication: where an order is passed without affording the department a fair hearing, the appellate authority may set aside the decision and remand for fresh adjudication. Section 128-A permits referring matters back when principles of natural justice were not followed, and authorities must give clear reasons for orders. The impugned Commissioner (Appeals) order was found to breach natural justice and was set aside, with directions to decide the appeals de novo after giving both sides opportunity to be heard.
Natural justice and audi alteram partem obligations govern appellate adjudication: where an order is passed without affording the department a fair hearing, the appellate authority may set aside the decision and remand for fresh adjudication. Section 128-A permits referring matters back when principles of natural justice were not followed, and authorities must give clear reasons for orders. The impugned Commissioner (Appeals) order was found to breach natural justice and was set aside, with directions to decide the appeals de novo after giving both sides opportunity to be heard.
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