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...
Deduction for additional employee cost could not be denied merely because Form No. 10DA was uploaded after the due date, where the assessee had obtained the form in time, attempted upload before the deadline, and the delay arose from technical glitches in the e-filing portal. The form was already on record before the return of income was filed and was available when the return was processed, so the Tribunal followed co-ordinate Bench rulings and directed the Assessing Officer to admit the form and allow the deduction in accordance with law. The Department's objection based on a later rejection under section 119(2)(b) was not accepted.
Deduction for additional employee cost could not be denied merely because Form No. 10DA was uploaded after the due date, where the assessee had obtained the form in time, attempted upload before the deadline, and the delay arose from technical glitches in the e-filing portal. The form was already on record before the return of income was filed and was available when the return was processed, so the Tribunal followed co-ordinate Bench rulings and directed the Assessing Officer to admit the form and allow the deduction in accordance with law. The Department's objection based on a later rejection under section 119(2)(b) was not accepted.
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