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...
Quantum of the household expenses - the assessee has not furnished any information qua to the household expenses. Thus there remains no alternate except to estimate the household expenses on reasonable basis. In this connection, we find that the learned CIT (A) has treated an amount of ₹ 6 lakhs as household expenses but failed to bring any basis for the estimation of such expenses. Therefore in interest of justice and fair play, we deemed it appropriate to treat such expenses to the tune of ₹ 3 Lacs only. It is also important to note that such household expenses should not be taken as the precedent for any other case of the assessee. It is just on ad hoc basis. - AT
Quantum of the household expenses - the assessee has not furnished any information qua to the household expenses. Thus there remains no alternate except to estimate the household expenses on reasonable basis. In this connection, we find that the learned CIT (A) has treated an amount of ₹ 6 lakhs as household expenses but failed to bring any basis for the estimation of such expenses. Therefore in interest of justice and fair play, we deemed it appropriate to treat such expenses to the tune of ₹ 3 Lacs only. It is also important to note that such household expenses should not be taken as the precedent for any other case of the assessee. It is just on ad hoc basis. - AT
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