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...
Nature of income - Since the assessee admittedly offered the income in his return pursuant to notice u/s 148 of the Act, which has been accepted by the AO as such, in my considered opinion, the ld. CIT(A) was not justified in countenancing the action of AO in treating additional income as unexplained cash credit or unexplained investment attracting sections 68 or 69 of the Act and consequently charging higher rate of taxation. - AT
Nature of income - Since the assessee admittedly offered the income in his return pursuant to notice u/s 148 of the Act, which has been accepted by the AO as such, in my considered opinion, the ld. CIT(A) was not justified in countenancing the action of AO in treating additional income as unexplained cash credit or unexplained investment attracting sections 68 or 69 of the Act and consequently charging higher rate of taxation. - AT
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