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 made on account of non realization of ‘Provision for surcharge’- such amount of surcharge cannot be held to be taxable as it is not the real income of the assessee and is hypothetical by nature - AT
Addition made on account of non realization of ‘Provision for surcharge’- such amount of surcharge cannot be held to be taxable as it is not the real income of the assessee and is hypothetical by nature - AT
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