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 by CIT - Depreciation on road and toll bridge constructed by the assessee - Tribunal has erred in concluding that the Assessing Officer has taken one of the plausible view before for the benefit of depreciation at 25% on “Toll Road” as “Plant”. - In our view, such view was not plausible as “ Toll Roads’ under the concessionaire agreement neither conferred upon the said assessee any “Tangible Assets” nor “Intangible Assets” - Decided in favor of revenue. - HC
Revision u/s 263 by CIT - Depreciation on road and toll bridge constructed by the assessee - Tribunal has erred in concluding that the Assessing Officer has taken one of the plausible view before for the benefit of depreciation at 25% on “Toll Road” as “Plant”. - In our view, such view was not plausible as “ Toll Roads’ under the concessionaire agreement neither conferred upon the said assessee any “Tangible Assets” nor “Intangible Assets” - Decided in favor of revenue. - HC
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