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...
Onus on assessee to explain exorbitant increase in transport expenses and support with proper bills/vouchers, which assessee failed. Sample bills/vouchers not for transport expense, lacking lorry details, origin and destination. Bills for purchase of materials like sand, mentioning 'transportation' but not actual transport expenses. Evidence not explaining abnormal increase in transport expense despite substantial increase in petrol expense. Cogent explanation and complete bills/vouchers lacking, hence addition confirmed by CIT(A) upheld by ITAT. Decided against assessee.
Onus on assessee to explain exorbitant increase in transport expenses and support with proper bills/vouchers, which assessee failed. Sample bills/vouchers not for transport expense, lacking lorry details, origin and destination. Bills for purchase of materials like sand, mentioning 'transportation' but not actual transport expenses. Evidence not explaining abnormal increase in transport expense despite substantial increase in petrol expense. Cogent explanation and complete bills/vouchers lacking, hence addition confirmed by CIT(A) upheld by ITAT. Decided against assessee.
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