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...
Addition u/s 69A - respondent/assessee is a Non-Resident Indian and his source of income in India being from interest on bank accounts and interest on income tax refund - Assessee is not required to maintain books of accounts - It appears to us prima facie that the expression “if any” specifically used in Section 69A of the Act amplifies that where books of account are not maintained, it would not be possible to invoke this provision. - Order of ITAT deleting the additions u/ 69A sustained - HC
Addition u/s 69A - respondent/assessee is a Non-Resident Indian and his source of income in India being from interest on bank accounts and interest on income tax refund - Assessee is not required to maintain books of accounts - It appears to us prima facie that the expression “if any” specifically used in Section 69A of the Act amplifies that where books of account are not maintained, it would not be possible to invoke this provision. - Order of ITAT deleting the additions u/ 69A sustained - HC
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