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...
Penalty u/s 271(1)(c) - TP addition - if the assessee computed the ALP of the international transaction as per the manner prescribed in good faith and due diligence then simply because now there remains some difference in the manner of determination of the ALP, it cannot be held that the assessee either concealed the particulars of its income or furnished inaccurate particulars of income - no penalty
Penalty u/s 271(1)(c) - TP addition - if the assessee computed the ALP of the international transaction as per the manner prescribed in good faith and due diligence then simply because now there remains some difference in the manner of determination of the ALP, it cannot be held that the assessee either concealed the particulars of its income or furnished inaccurate particulars of income - no penalty
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