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...
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
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