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 quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
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