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...
Assessee entitled to claim depreciation on leased assets despite revenue's contention that transactions were mere financial transactions lacking ownership and usage for business purpose. Supreme Court's decision in I.C.D.S. case applicable, rejecting revenue's argument based on lease agreement clauses. Mere academic ownership shown to claim depreciation cannot disentitle depreciation u/s 32. Regarding interest u/s 220(2), ITAT rightly held it chargeable only up to original assessment order u/s 143(3) or 144, not up to order u/s 143(3) read with Section 254. Depreciation on leased assets allowed, consequently no further interest payable after assessment order.
Assessee entitled to claim depreciation on leased assets despite revenue's contention that transactions were mere financial transactions lacking ownership and usage for business purpose. Supreme Court's decision in I.C.D.S. case applicable, rejecting revenue's argument based on lease agreement clauses. Mere academic ownership shown to claim depreciation cannot disentitle depreciation u/s 32. Regarding interest u/s 220(2), ITAT rightly held it chargeable only up to original assessment order u/s 143(3) or 144, not up to order u/s 143(3) read with Section 254. Depreciation on leased assets allowed, consequently no further interest payable after assessment order.
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