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 - The fact that the vouchers were not found in the premises of the appellant trust at the time of survey proceedings, should have triggered the AO to enquire and verify the evidence of the expenditure incurred on those items such as “Bonus, Perks and Allowances, Office Expenses, Tours and Travelling Expenses, Building Repairs Expenses etc”, which the AO had failed to do so. Therefore, this fact clearly demonstrates that the AO had failed to conduct necessary enquiries - Revision order sustained - AT
Revision u/s 263 - The fact that the vouchers were not found in the premises of the appellant trust at the time of survey proceedings, should have triggered the AO to enquire and verify the evidence of the expenditure incurred on those items such as “Bonus, Perks and Allowances, Office Expenses, Tours and Travelling Expenses, Building Repairs Expenses etc”, which the AO had failed to do so. Therefore, this fact clearly demonstrates that the AO had failed to conduct necessary enquiries - Revision order sustained - AT
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