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 ITAT held that the assessee failed to explain the nature and source of investment with necessary supporting evidence. The PCIT's action invoking section 263 was in accordance with statutory provisions. While the AO should have taxed Rs. 14,93,393/- u/s 56(2)(x) and Rs. 33,18,000/- u/s 69 instead of the entire stamp duty value, the matter was set aside to the PCIT for further inquiry regarding year of purchase, purchase cost, and date-wise payments to determine the amount of investment u/s 69. The assessee's appeal was partly allowed for statistical purposes.
The ITAT held that the assessee failed to explain the nature and source of investment with necessary supporting evidence. The PCIT's action invoking section 263 was in accordance with statutory provisions. While the AO should have taxed Rs. 14,93,393/- u/s 56(2)(x) and Rs. 33,18,000/- u/s 69 instead of the entire stamp duty value, the matter was set aside to the PCIT for further inquiry regarding year of purchase, purchase cost, and date-wise payments to determine the amount of investment u/s 69. The assessee's appeal was partly allowed for statistical purposes.
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