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...
Bogus purchase bills from certain ‘hawala’ dealers - The Tribunal found the assessee failed to substantiate the genuineness of the purchases from alleged Hawala dealers, with various evidences like returned notices, inability to produce vendors, and lack of stock register verification supporting the Assessing Officer's conclusions. - The Tribunal rejected the assessee's argument for restricting disallowance to a certain percentage of gross profit, emphasizing the absence of concrete evidence like a stock register to establish the actual receipt and sale of goods corresponding to the bogus purchases. - Addition against entire amount of bogus purchase confirmed.
Bogus purchase bills from certain ‘hawala’ dealers - The Tribunal found the assessee failed to substantiate the genuineness of the purchases from alleged Hawala dealers, with various evidences like returned notices, inability to produce vendors, and lack of stock register verification supporting the Assessing Officer's conclusions. - The Tribunal rejected the assessee's argument for restricting disallowance to a certain percentage of gross profit, emphasizing the absence of concrete evidence like a stock register to establish the actual receipt and sale of goods corresponding to the bogus purchases. - Addition against entire amount of bogus purchase confirmed.
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