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...
Estimation of income - Bogus purchases - Reliance on retracted statement - The ITAT, after reviewing the case, noted discrepancies in the reliance on these statements for making disallowances. They observed that subsequent affidavits retracted these statements, diminishing their evidentiary value. Additionally, documentary evidence such as invoices and bank statements corroborated the assessee's claims of genuine purchases. For several assessment years, the tribunal decided to delete the disallowances concerning bogus purchases, arguing that the AO's assessments were based on inadequate grounds and, in some cases, relied excessively on ad-hoc estimates.
Estimation of income - Bogus purchases - Reliance on retracted statement - The ITAT, after reviewing the case, noted discrepancies in the reliance on these statements for making disallowances. They observed that subsequent affidavits retracted these statements, diminishing their evidentiary value. Additionally, documentary evidence such as invoices and bank statements corroborated the assessee's claims of genuine purchases. For several assessment years, the tribunal decided to delete the disallowances concerning bogus purchases, arguing that the AO's assessments were based on inadequate grounds and, in some cases, relied excessively on ad-hoc estimates.
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