Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
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...
The key points are: The Assessing Officer (AO) erroneously applied Section 69C of the Income Tax Act, which deals with unexplained expenditure, to transactions involving sales to SINPL. The Income Tax Appellate Tribunal (ITAT) held that since the assessee provided accommodation entries, only the profit element on the sales should be added to the income. The assessee admitted that a higher commission rate of 5% could be treated as profit on the accommodation entry transactions of Rs. 34,59,840/-. The ITAT directed the AO to apply the 5% profit rate, amounting to Rs. 1,73,000/-, and add it to the assessee's disclosed income, instead of the addition made u/s 69C.
The key points are: The Assessing Officer (AO) erroneously applied Section 69C of the Income Tax Act, which deals with unexplained expenditure, to transactions involving sales to SINPL. The Income Tax Appellate Tribunal (ITAT) held that since the assessee provided accommodation entries, only the profit element on the sales should be added to the income. The assessee admitted that a higher commission rate of 5% could be treated as profit on the accommodation entry transactions of Rs. 34,59,840/-. The ITAT directed the AO to apply the 5% profit rate, amounting to Rs. 1,73,000/-, and add it to the assessee's disclosed income, instead of the addition made u/s 69C.
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