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...
Loss arising on account of exchange fluctuation - The analysis done by the ITAT and the conclusion arrived at in respect of the subject claim of the appellant being the correct approach consistent with the exposition of this Court, needs to be upheld. In our opinion, the High Court missed the relevant aspects of the analysis of the ITAT concerning the fact situation of the present case. As a matter of fact, the High Court has not even adverted to the aforementioned reported decisions, much less its usefulness in the present case. - The impugned judgment and order of the High Court needs to be set aside and instead, the decision of the ITAT in favour of the appellant on the two questions examined by the High Court in the impugned judgment, needs to be affirmed and restored - SC
Loss arising on account of exchange fluctuation - The analysis done by the ITAT and the conclusion arrived at in respect of the subject claim of the appellant being the correct approach consistent with the exposition of this Court, needs to be upheld. In our opinion, the High Court missed the relevant aspects of the analysis of the ITAT concerning the fact situation of the present case. As a matter of fact, the High Court has not even adverted to the aforementioned reported decisions, much less its usefulness in the present case. - The impugned judgment and order of the High Court needs to be set aside and instead, the decision of the ITAT in favour of the appellant on the two questions examined by the High Court in the impugned judgment, needs to be affirmed and restored - SC
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