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 credit - capital contribution in cash by the partners - While deleting the additions, the Tribunal held that, if the Ld. AO was not convinced with the source of amounts deposited by the partners, then such addition could have been made in the hands of such partners by invoking the relevant provisions of law but no addition was called for in the case of assessee firm, who have discharged its primary onus u/s 68 by providing the details of the partners from whom such funds were received.
Addition u/s 68 - unexplained cash credit - capital contribution in cash by the partners - While deleting the additions, the Tribunal held that, if the Ld. AO was not convinced with the source of amounts deposited by the partners, then such addition could have been made in the hands of such partners by invoking the relevant provisions of law but no addition was called for in the case of assessee firm, who have discharged its primary onus u/s 68 by providing the details of the partners from whom such funds were received.
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