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...
Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.
Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.
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