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...
Unexplained cash credit u/s 68 - AO made addition of loan based on statement of a person who retract subsequently - it is the revenue which had placed reliance on the statement hence it is the duty of the revenue to produce the party as their witness in order to enable the assessee to cross examine the said party, if it so desires and this responsibility cannot be shifted to the assessee by the AO - no addition based on that statement
Unexplained cash credit u/s 68 - AO made addition of loan based on statement of a person who retract subsequently - it is the revenue which had placed reliance on the statement hence it is the duty of the revenue to produce the party as their witness in order to enable the assessee to cross examine the said party, if it so desires and this responsibility cannot be shifted to the assessee by the AO - no addition based on that statement
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