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 - unexplained expenditure on account of cash payment made towards land - the addition made by the A.O. and upheld by the ld. CIT(A) on the basis of seized document is without any basis or foundation more particularly when no specific facts by virtue of documents have been placed on record and have not rebutted by the Revenue, thus, in this eventuality, no addition was warranted. - AT
Assessment u/s 153A - unexplained expenditure on account of cash payment made towards land - the addition made by the A.O. and upheld by the ld. CIT(A) on the basis of seized document is without any basis or foundation more particularly when no specific facts by virtue of documents have been placed on record and have not rebutted by the Revenue, thus, in this eventuality, no addition was warranted. - AT
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