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...
Unaccounted investment recorded in the seized document - No registered document whatsoever was found during the course of search, - No summons were issued to Sub-Registrar to find out as to whether any such document referred to in the paper was readly executed in favour of assessee or not, he had simply presumed that the figures were unaccounted investment made by the assessee for the year under consideration, without there being any material on record to support such presumption. - Additions were rightly deleted by the CIT(A) - AT
Unaccounted investment recorded in the seized document - No registered document whatsoever was found during the course of search, - No summons were issued to Sub-Registrar to find out as to whether any such document referred to in the paper was readly executed in favour of assessee or not, he had simply presumed that the figures were unaccounted investment made by the assessee for the year under consideration, without there being any material on record to support such presumption. - Additions were rightly deleted by the CIT(A) - AT
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