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...
Transfer pricing adjustment - AO/TPO/DRP not appreciating the 50:50 revenue split business model between the appellant and its associated enterprises in relation to international transactions, i.e. provision and receipt of freight forwarding services, and, further making an upward adjustment alleging that such transactions were not at arm’s length - TNMM v/s CUP method? - AT
Transfer pricing adjustment - AO/TPO/DRP not appreciating the 50:50 revenue split business model between the appellant and its associated enterprises in relation to international transactions, i.e. provision and receipt of freight forwarding services, and, further making an upward adjustment alleging that such transactions were not at arm’s length - TNMM v/s CUP method? - AT
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