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...
Section 143(1)(a) permits only summary adjustments apparent from the return, not resolution of a debatable deduction issue. On the date of intimation, whether employees' contribution to ESI and EPF deposited after the due date under the labour laws but before filing the return was allowable was already subject to conflicting judicial views. The disclosed delay in the audit report did not make the disallowance self-evident, and the Assessing Officer could not treat the claim as a prima facie adjustment. The intimation and appellate orders were set aside, with liberty to the Revenue to proceed by regular assessment in accordance with law.
Section 143(1)(a) permits only summary adjustments apparent from the return, not resolution of a debatable deduction issue. On the date of intimation, whether employees' contribution to ESI and EPF deposited after the due date under the labour laws but before filing the return was allowable was already subject to conflicting judicial views. The disclosed delay in the audit report did not make the disallowance self-evident, and the Assessing Officer could not treat the claim as a prima facie adjustment. The intimation and appellate orders were set aside, with liberty to the Revenue to proceed by regular assessment in accordance with law.
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