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 - on-money in land transaction - simply because the buyer did not say anything about the ‘on money payment’, statement of the assessee in the absence of any contrary evidence can’t be rejected. The AO has made the addition u/s 68 of the Act. This Section applies when any sum is found credited in the books of accounts, source of which is not explained to the satisfaction of the AO. Noting on a paper can’t be said to be an entry in the books of accounts. -additions deleted - AT
Assessment u/s 153A - on-money in land transaction - simply because the buyer did not say anything about the ‘on money payment’, statement of the assessee in the absence of any contrary evidence can’t be rejected. The AO has made the addition u/s 68 of the Act. This Section applies when any sum is found credited in the books of accounts, source of which is not explained to the satisfaction of the AO. Noting on a paper can’t be said to be an entry in the books of accounts. -additions deleted - AT
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