Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
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