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...
Approval under section 148B must reflect independent consideration of the draft assessment order, proposed additions and supporting material; a bare grant of approval is a mechanical exercise and invalid. The Tribunal held that the approving authority must indicate some application of mind in the approval record, failing which the safeguard becomes an empty formality. Applying that principle, it found the approvals in the connected matters invalid and treated the consequential assessments as non est in law, without examining the merits.
Approval under section 148B must reflect independent consideration of the draft assessment order, proposed additions and supporting material; a bare grant of approval is a mechanical exercise and invalid. The Tribunal held that the approving authority must indicate some application of mind in the approval record, failing which the safeguard becomes an empty formality. Applying that principle, it found the approvals in the connected matters invalid and treated the consequential assessments as non est in law, without examining the merits.
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