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 - Creditworthiness of the Loan Lender - Genuineness of the Transaction - The Tribunal set aside the matter to the AO for a thorough examination of the creditworthiness of the loan lender. The appellant is required to furnish all necessary documents to establish the authenticity and creditworthiness of the loan creditor. The AO is instructed to allow reasonable opportunity for the appellant to present supporting evidence.
Addition u/s 68 - Creditworthiness of the Loan Lender - Genuineness of the Transaction - The Tribunal set aside the matter to the AO for a thorough examination of the creditworthiness of the loan lender. The appellant is required to furnish all necessary documents to establish the authenticity and creditworthiness of the loan creditor. The AO is instructed to allow reasonable opportunity for the appellant to present supporting evidence.
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