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...
Validity of assessment u/s 153C - real owner of the document seized - the presumption cast under provisions of section 132(4A) of the Act, comes into play. - even the provisions of section 292C(1) also provide the same. This presumption was not rebutted by the AO of the searched person - assessee-firm cannot be said to be the owner of the document seized. - AT
Validity of assessment u/s 153C - real owner of the document seized - the presumption cast under provisions of section 132(4A) of the Act, comes into play. - even the provisions of section 292C(1) also provide the same. This presumption was not rebutted by the AO of the searched person - assessee-firm cannot be said to be the owner of the document seized. - AT
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