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 - Bogus LTCG - Penny stock transactions - The Tribunal found that the assessee had provided sufficient documentary evidence supporting the genuineness of the transactions, including purchase and sale of shares through the Bombay Stock Exchange (BSE), payment through banking channels, and compliance with regulatory requirements (like STT). - ITAT noted that the AO primarily relied on a general report by the Kolkata Investigation wing and failed to connect the assessee or their transactions directly to any alleged manipulation of share prices. Additionally, SEBI did not find any wrongdoing on the part of the assessee or their broker. - Given the genuineness of the LTCG transactions was established, the Tribunal agreed with the CIT(A)'s decision to delete the addition.
Addition u/s 68 - Bogus LTCG - Penny stock transactions - The Tribunal found that the assessee had provided sufficient documentary evidence supporting the genuineness of the transactions, including purchase and sale of shares through the Bombay Stock Exchange (BSE), payment through banking channels, and compliance with regulatory requirements (like STT). - ITAT noted that the AO primarily relied on a general report by the Kolkata Investigation wing and failed to connect the assessee or their transactions directly to any alleged manipulation of share prices. Additionally, SEBI did not find any wrongdoing on the part of the assessee or their broker. - Given the genuineness of the LTCG transactions was established, the Tribunal agreed with the CIT(A)'s decision to delete the addition.
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