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...
Issue: imposition of penalty under section 271(1)(b) for failure to comply with notices under section 142(1). Principle applied: the onus lies on the assessee to show bona fide and reasonable cause and to disclose material facts; Revenue need not prove deliberate default. Outcome: where the assessee offered no substantiated explanation and assessment proceeded ex parte, subsequent belated compliance did not negate penalty. The ITAT upheld two penalties for separate non compliance occasions and dismissed the appeal for failure to prove reasonable cause.
Issue: imposition of penalty under section 271(1)(b) for failure to comply with notices under section 142(1). Principle applied: the onus lies on the assessee to show bona fide and reasonable cause and to disclose material facts; Revenue need not prove deliberate default. Outcome: where the assessee offered no substantiated explanation and assessment proceeded ex parte, subsequent belated compliance did not negate penalty. The ITAT upheld two penalties for separate non compliance occasions and dismissed the appeal for failure to prove reasonable cause.
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