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...
Reopening of assessment u/s 147 - additions of cash deposits - The Tribunal held that, the Assessing Officer has treated the cash deposit merely on the basis of human probability without bringing any adverse evidence on record that such cash deposit was unexplained money of assessee when the assessee was having sufficient money in his two NRE and one NRO account and explained the investment during the relevant period. - Additions directed to be deleted.
Reopening of assessment u/s 147 - additions of cash deposits - The Tribunal held that, the Assessing Officer has treated the cash deposit merely on the basis of human probability without bringing any adverse evidence on record that such cash deposit was unexplained money of assessee when the assessee was having sufficient money in his two NRE and one NRO account and explained the investment during the relevant period. - Additions directed to be deleted.
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