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...
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
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