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...
Taxation u/s 44BB - Existence of PE - contractual income from GSPC under the contract - drilling services were continued only for a period of 119 days - When the rig had entered Indian waters and it was undergoing fabrication, upgradation and positioning for the drilling activity for GSPC it can be said that the PE was there in connection with the exploration, exploitation or extraction of mineral oils. - Order of ITAT confirming the additions sustained - HC
Taxation u/s 44BB - Existence of PE - contractual income from GSPC under the contract - drilling services were continued only for a period of 119 days - When the rig had entered Indian waters and it was undergoing fabrication, upgradation and positioning for the drilling activity for GSPC it can be said that the PE was there in connection with the exploration, exploitation or extraction of mineral oils. - Order of ITAT confirming the additions sustained - HC
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