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...
Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
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