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...
Revision u/s 263 - When the Assessing Officer after exhaustive deliberations had accepted the explanation of the assessee and refrained from drawing any adverse inferences in its hand qua the issue in question i.e. contents of the seized loose sheet, therefore, the Pr. CIT in the garb of exercise of his revisionary jurisdiction u/s.263 of the Act could not have sought for substitution of his view as against that arrived at by the Assessing Officer. - AT
Revision u/s 263 - When the Assessing Officer after exhaustive deliberations had accepted the explanation of the assessee and refrained from drawing any adverse inferences in its hand qua the issue in question i.e. contents of the seized loose sheet, therefore, the Pr. CIT in the garb of exercise of his revisionary jurisdiction u/s.263 of the Act could not have sought for substitution of his view as against that arrived at by the Assessing Officer. - AT
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