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...
Addition u/s 40A - interest paid @ 18% in relation to the borrowing made from the persons specified u/s 40A(2)(b) - unreasonable and excessive expenditure - Once there was categorical findings by the Tribunal that 18% per annum interest was reasonable the CIT(A) ought to have followed the same. - AT
Addition u/s 40A - interest paid @ 18% in relation to the borrowing made from the persons specified u/s 40A(2)(b) - unreasonable and excessive expenditure - Once there was categorical findings by the Tribunal that 18% per annum interest was reasonable the CIT(A) ought to have followed the same. - AT
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