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...
Proceedings u/s 153A - addition of Unexplained cash credit U/s 68 - if there is no incriminating material to reassess the income of the assessee then the AO legally cannot make the addition based on the information and evidence received from the Inv.Wing - it is open to the AO to initiate the proceeding U/s 147/148 instead of making the addition in the proceeding U/s 153A
Proceedings u/s 153A - addition of Unexplained cash credit U/s 68 - if there is no incriminating material to reassess the income of the assessee then the AO legally cannot make the addition based on the information and evidence received from the Inv.Wing - it is open to the AO to initiate the proceeding U/s 147/148 instead of making the addition in the proceeding U/s 153A
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