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...
Unexplained cash credit u/s.68 - Mere repayment of the loans subsequently does not make the original acceptance of loan as genuine. Such an argument is against the language of the provision of section 68 of the act. Criteria of "identity, creditworthiness and genuineness" are to be tested at the time of amount credited in the books of the assessee. All subsequent events are immaterial. - AT
Unexplained cash credit u/s.68 - Mere repayment of the loans subsequently does not make the original acceptance of loan as genuine. Such an argument is against the language of the provision of section 68 of the act. Criteria of "identity, creditworthiness and genuineness" are to be tested at the time of amount credited in the books of the assessee. All subsequent events are immaterial. - AT
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