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...
ITAT reversed additions made under s.69A based on seized digital ledger "Hazir Johri." The disputed ledger "Sanmati 1586" contained merged entries of multiple unrelated parties alongside assessee's transactions. Revenue authorities failed to provide concrete evidence linking assessee to all transactions or substantiate the nature of entries where assessee was named. No corroborative documentation like bills, vouchers, or stock registers established cash sales attribution to assessee. Following precedent where similar merged ledgers were deemed insufficient basis for additions, ITAT held that reliance on Hazir Johri software alone cannot sustain additions without supporting evidence. Assessee's explanation was considered plausible, and additions were deleted.
ITAT reversed additions made under s.69A based on seized digital ledger "Hazir Johri." The disputed ledger "Sanmati 1586" contained merged entries of multiple unrelated parties alongside assessee's transactions. Revenue authorities failed to provide concrete evidence linking assessee to all transactions or substantiate the nature of entries where assessee was named. No corroborative documentation like bills, vouchers, or stock registers established cash sales attribution to assessee. Following precedent where similar merged ledgers were deemed insufficient basis for additions, ITAT held that reliance on Hazir Johri software alone cannot sustain additions without supporting evidence. Assessee's explanation was considered plausible, and additions were deleted.
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