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...
Disallowance of interest expenditure by applying provisions of section 40A(2)(b) - Specified / Related parties - Difference between the interest paid by assessee at 15% and the reasonable rate of interest ultimately allowed by learned Commissioner (Appeals) at 13.73% works out to a negligible amount of 1.27%. That being the case, in my considered opinion, the provisions of section 40A(2)(b) would not be applicable in the present case - AT
Disallowance of interest expenditure by applying provisions of section 40A(2)(b) - Specified / Related parties - Difference between the interest paid by assessee at 15% and the reasonable rate of interest ultimately allowed by learned Commissioner (Appeals) at 13.73% works out to a negligible amount of 1.27%. That being the case, in my considered opinion, the provisions of section 40A(2)(b) would not be applicable in the present case - AT
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