Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
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 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the identity, creditworthiness, and genuineness of the transaction. - The ITAT held that, in view of such facts the observations of Ld. AO cannot be rejected at threshold, in absence of submission of requisite documents pertaining to the alleged creditor by the assessee having primary onus to satisfy the Ld. AO according to the provisions of section 68, who is supporting its contentions only by producing certain internal documents and bank statements. - Therefore, the addition made by the AO under section 68 was upheld.
Addition u/s 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the identity, creditworthiness, and genuineness of the transaction. - The ITAT held that, in view of such facts the observations of Ld. AO cannot be rejected at threshold, in absence of submission of requisite documents pertaining to the alleged creditor by the assessee having primary onus to satisfy the Ld. AO according to the provisions of section 68, who is supporting its contentions only by producing certain internal documents and bank statements. - Therefore, the addition made by the AO under section 68 was upheld.
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