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...
Addition u/s. 56(2)(viib) - shares issued at premium - Valuation under rule 11UA - The argument of the assessee is not acceptable because rules are applicable to year under assessment. - As the shares were allotted during the year under consideration, i.e. 2013-14 itself, Rule 11UA become applicable from 2013- 14 itself. - AT
Addition u/s. 56(2)(viib) - shares issued at premium - Valuation under rule 11UA - The argument of the assessee is not acceptable because rules are applicable to year under assessment. - As the shares were allotted during the year under consideration, i.e. 2013-14 itself, Rule 11UA become applicable from 2013- 14 itself. - AT
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