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 assessment for AY 2008-09 initiated u/s 153A was beyond the 10-year limitation period prescribed, rendering the assessment order invalid. However, regarding the addition of share capital and share premium u/s 153A, the ITAT upheld the CIT(A)'s finding of incriminating material, validating the assessment order, relying on the Goldstone Cements Ltd. case. The appeals were partly allowed and partly dismissed.
The ITAT held that the assessment for AY 2008-09 initiated u/s 153A was beyond the 10-year limitation period prescribed, rendering the assessment order invalid. However, regarding the addition of share capital and share premium u/s 153A, the ITAT upheld the CIT(A)'s finding of incriminating material, validating the assessment order, relying on the Goldstone Cements Ltd. case. The appeals were partly allowed and partly dismissed.
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