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 153C r.w.s. 143(3) of the Act OR u/s 143(3) - AO made addition to the total income of the assessee on account of undisclosed investment in construction of project solely on the basis of valuation report of the DVO which in itself is unsustainable in light of the fact that no incriminating material was found during the course of search thereby warranting such addition to the total income of the assessee. - AT
Assessment u/s 153C r.w.s. 143(3) of the Act OR u/s 143(3) - AO made addition to the total income of the assessee on account of undisclosed investment in construction of project solely on the basis of valuation report of the DVO which in itself is unsustainable in light of the fact that no incriminating material was found during the course of search thereby warranting such addition to the total income of the assessee. - AT
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