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...
Disallowance of interest - diversion of funds for a non-business purpose - owned fund of the assessee as on 31st March 2013 and 31st March 2014 is more than the amount of advances given at a lower rate of interest which is not in dispute - a presumption can be drawn that the assessee has advanced the money to the relatives of the partners out of its fund - no disallowance
Disallowance of interest - diversion of funds for a non-business purpose - owned fund of the assessee as on 31st March 2013 and 31st March 2014 is more than the amount of advances given at a lower rate of interest which is not in dispute - a presumption can be drawn that the assessee has advanced the money to the relatives of the partners out of its fund - no disallowance
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