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 - adjustment to the arm’s length price of the advertisement services received from the associated enterprise - Since the agreement is also silent, we do not accept that the assessee could utilize the basket of adslots and aggregate the same for achieving the target. - AT
Transfer pricing adjustment - adjustment to the arm’s length price of the advertisement services received from the associated enterprise - Since the agreement is also silent, we do not accept that the assessee could utilize the basket of adslots and aggregate the same for achieving the target. - AT
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