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 of the suppressed gross receipts as were disclosed by the assessee company during the survey proceedings u/s. 133A - The AO initially added the entire unrecorded amount as income, but the Tribunal agreed with the Commissioner's approach that only the profit element should be taxed. This decision was based on the principle that the total sales could not be regarded as profit and was supported by various judicial precedents.
Addition of the suppressed gross receipts as were disclosed by the assessee company during the survey proceedings u/s. 133A - The AO initially added the entire unrecorded amount as income, but the Tribunal agreed with the Commissioner's approach that only the profit element should be taxed. This decision was based on the principle that the total sales could not be regarded as profit and was supported by various judicial precedents.
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