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...
TP Adjustment u/s 40A(2) r.w.s 37 - management fee - Neither the TPO nor the AO have brought any material on record indicating the assessee’s excessive impugned payments as the statutory provision in question is applicable only for excessive component of the relevant heads of the expenditure than that in entirety - the CIT(A) action deleting the upward adjustment is affirmed
TP Adjustment u/s 40A(2) r.w.s 37 - management fee - Neither the TPO nor the AO have brought any material on record indicating the assessee’s excessive impugned payments as the statutory provision in question is applicable only for excessive component of the relevant heads of the expenditure than that in entirety - the CIT(A) action deleting the upward adjustment is affirmed
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