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...
TP Adjustment made by excluding two comparable companies due to excessive related party transactions, rendering them un-comparable. Other comparables to be considered for arm's length price computation. AO's jurisdiction over expenditure for support services upheld as consistent with TPO's acceptance over the years. Cost allocation methodology change disallowed. Depreciation allowance for intangible assets like customer contracts and workforce granted at 25% rate based on ITAT decision in the assessee's favor. Additional ground raised allowed.
TP Adjustment made by excluding two comparable companies due to excessive related party transactions, rendering them un-comparable. Other comparables to be considered for arm's length price computation. AO's jurisdiction over expenditure for support services upheld as consistent with TPO's acceptance over the years. Cost allocation methodology change disallowed. Depreciation allowance for intangible assets like customer contracts and workforce granted at 25% rate based on ITAT decision in the assessee's favor. Additional ground raised allowed.
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