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...
Deduction u/s 35AD and set off u/s 73A against the loss incurred by it in other unit - Loss of assessee on account of a specified business claiming deduction u/s 35AD would be allowed to set of against the profit of another specified business. U/s 73A, whether or not the later is eligible for deduction u/s 35AD. Therefore, by the above clarification, it is clear that assessee can claim set off against the profit from specified business units of Mumbai and Indore. - AT
Deduction u/s 35AD and set off u/s 73A against the loss incurred by it in other unit - Loss of assessee on account of a specified business claiming deduction u/s 35AD would be allowed to set of against the profit of another specified business. U/s 73A, whether or not the later is eligible for deduction u/s 35AD. Therefore, by the above clarification, it is clear that assessee can claim set off against the profit from specified business units of Mumbai and Indore. - AT
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