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 original return was only processed under section 143(1), there was no assessment order reflecting formation of opinion, so reopening could not be struck down as a mere change of opinion and the Tribunal could examine the jurisdictional issue. On merits, interest earned on deposits of funds earmarked for acquisition of technical know-how, land, machinery and other project commitments had a direct nexus with setting up the manufacturing business. Such receipts were therefore to be adjusted against pre-operative expenditure and not taxed as income from other sources. The High Court upheld reassessment but rejected the Revenue's treatment of the interest as taxable income.
Where the original return was only processed under section 143(1), there was no assessment order reflecting formation of opinion, so reopening could not be struck down as a mere change of opinion and the Tribunal could examine the jurisdictional issue. On merits, interest earned on deposits of funds earmarked for acquisition of technical know-how, land, machinery and other project commitments had a direct nexus with setting up the manufacturing business. Such receipts were therefore to be adjusted against pre-operative expenditure and not taxed as income from other sources. The High Court upheld reassessment but rejected the Revenue's treatment of the interest as taxable income.
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