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...
Validity of reopening of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
Validity of reopening of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
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