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...
Assessment u/s 153A - Deemed dividend addition u/s 2(22)(e) - whether the statement recorded during search u/s 132(4) of the Act or extracts of books of accounts maintained by the assessee constitute incriminating materials found during search or not? - a statement recorded during the course of search can not be considered an incriminating material in order to make addition in an unabated assessment year - AT
Assessment u/s 153A - Deemed dividend addition u/s 2(22)(e) - whether the statement recorded during search u/s 132(4) of the Act or extracts of books of accounts maintained by the assessee constitute incriminating materials found during search or not? - a statement recorded during the course of search can not be considered an incriminating material in order to make addition in an unabated assessment year - AT
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