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 investment - Addition u/s 69/69B - An agreement even itself will not be enforceable in the eyes of law unless character of the land is changed viz. it is being converted into new tenure and such conversion is depended upon the payment of premium to the Government, and sanction from the Government. In these situations, it is difficult to infer that the assessee would pay on-money before such incident of conversion happen. This was the positive evidence produced by the assessees for rebutting the belief formed by the AO - CIT(A) rightly deleted the additions - AT
Unexplained investment - Addition u/s 69/69B - An agreement even itself will not be enforceable in the eyes of law unless character of the land is changed viz. it is being converted into new tenure and such conversion is depended upon the payment of premium to the Government, and sanction from the Government. In these situations, it is difficult to infer that the assessee would pay on-money before such incident of conversion happen. This was the positive evidence produced by the assessees for rebutting the belief formed by the AO - CIT(A) rightly deleted the additions - AT
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