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...
Charitable payment-system infrastructure operated for public benefit remained eligible for exemption under sections 11 and 12 despite transaction-based fees and surplus generation. Fee collection did not by itself establish commercial activity under the proviso to section 2(15), particularly where services were uniformly available at the same fee. No application of income for the benefit of specified persons was established under section 13(3). On identical facts to an earlier coordinate Bench ruling, exemption was sustained for both assessment years and the Revenue's appeals were dismissed.
Charitable payment-system infrastructure operated for public benefit remained eligible for exemption under sections 11 and 12 despite transaction-based fees and surplus generation. Fee collection did not by itself establish commercial activity under the proviso to section 2(15), particularly where services were uniformly available at the same fee. No application of income for the benefit of specified persons was established under section 13(3). On identical facts to an earlier coordinate Bench ruling, exemption was sustained for both assessment years and the Revenue's appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
