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...
Buy-back of a company's own shares followed by mandatory extinguishment does not entail receipt of "property" for section 56(2)(x), because the shares cannot be held, enjoyed or transferred by the company as an asset. Interest-free advances do not justify interest disallowance under section 36(1)(iii) where interest-free own funds exceed those advances and no specific borrowing is traceable to them; proportionate disallowance from a mixed pool of funds is unwarranted. Principal loans and inter-corporate deposits written off in an organised money-lending business qualify as bad debts where actual write-off occurs. A lending licence, tax-audit description and the proportion of interest income are not determinative of that business character.
Buy-back of a company's own shares followed by mandatory extinguishment does not entail receipt of "property" for section 56(2)(x), because the shares cannot be held, enjoyed or transferred by the company as an asset. Interest-free advances do not justify interest disallowance under section 36(1)(iii) where interest-free own funds exceed those advances and no specific borrowing is traceable to them; proportionate disallowance from a mixed pool of funds is unwarranted. Principal loans and inter-corporate deposits written off in an organised money-lending business qualify as bad debts where actual write-off occurs. A lending licence, tax-audit description and the proportion of interest income are not determinative of that business character.
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