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...
For a search assessment of an "other person" under section 153C, the relevant date for identifying the block of assessment years is when the seized material is handed over by the searched person's Assessing Officer to the jurisdictional Assessing Officer. As the satisfaction and handing over occurred on 26.03.2019, AY 2017-18 fell within the section 153C block. The AO's resort to section 143(3) was therefore without valid jurisdiction, and the assessment for AY 2017-18 was invalid on that basis. The ITAT upheld the Commissioner (Appeals) and rejected the Revenue's challenge.
For a search assessment of an "other person" under section 153C, the relevant date for identifying the block of assessment years is when the seized material is handed over by the searched person's Assessing Officer to the jurisdictional Assessing Officer. As the satisfaction and handing over occurred on 26.03.2019, AY 2017-18 fell within the section 153C block. The AO's resort to section 143(3) was therefore without valid jurisdiction, and the assessment for AY 2017-18 was invalid on that basis. The ITAT upheld the Commissioner (Appeals) and rejected the Revenue's challenge.
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