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...
Estimation of income - AO has made 100% addition, whereas the CIT(A) has scaled down addition to 12.50% profit on alleged bogus purchases. - Although, both authorities have taken different rate of profit for estimation of income from alleged bogus purchase, but no one could support said rate of gross profit with necessary evidences or any comparable cases. We are of the considered opinion that 12.50% rate of profit adopted by the CIT(A) appears to be reasonable - AT
Estimation of income - AO has made 100% addition, whereas the CIT(A) has scaled down addition to 12.50% profit on alleged bogus purchases. - Although, both authorities have taken different rate of profit for estimation of income from alleged bogus purchase, but no one could support said rate of gross profit with necessary evidences or any comparable cases. We are of the considered opinion that 12.50% rate of profit adopted by the CIT(A) appears to be reasonable - AT
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