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...
TPA - MAM selection - CUP or TNMM - if the intra AE transactions were fundamentally different in character in economic circumstances and contractual terms then these cannot be compared with the independent transactions entered into by the assessee - the availability, coverage and reliability of data necessary for application of the method - CUP rejected
TPA - MAM selection - CUP or TNMM - if the intra AE transactions were fundamentally different in character in economic circumstances and contractual terms then these cannot be compared with the independent transactions entered into by the assessee - the availability, coverage and reliability of data necessary for application of the method - CUP rejected
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