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...
Disallowance of deduction u/s 10B - The tribunal examined the appellant's claim regarding deductions under Section 10B for miscellaneous incomes like scrap sales and tool development income. It referred to judicial precedents and the Act's provisions, concluding that such incomes, being integral to the business operations of Export Oriented Units (EOUs), qualify for deduction under Section 10B. This interpretation aligns with the legislative intent to encourage exports by offering tax incentives for incomes directly related to the business activity of EOUs.
Disallowance of deduction u/s 10B - The tribunal examined the appellant's claim regarding deductions under Section 10B for miscellaneous incomes like scrap sales and tool development income. It referred to judicial precedents and the Act's provisions, concluding that such incomes, being integral to the business operations of Export Oriented Units (EOUs), qualify for deduction under Section 10B. This interpretation aligns with the legislative intent to encourage exports by offering tax incentives for incomes directly related to the business activity of EOUs.
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