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 dismissed the Revenue's appeal regarding rectification u/s 154, finding no prima facie mistake apparent from records. The tribunal concluded that the deduction u/s 80IA(12A) was comprehensively examined by CIT(A), and the provisions of section 154 could not be invoked to modify the assessee's claim. The AO was not justified in withdrawing the deduction claim under section 80IA(2A), and both legal grounds and case merits supported dismissal of the Revenue's appeal.
ITAT dismissed the Revenue's appeal regarding rectification u/s 154, finding no prima facie mistake apparent from records. The tribunal concluded that the deduction u/s 80IA(12A) was comprehensively examined by CIT(A), and the provisions of section 154 could not be invoked to modify the assessee's claim. The AO was not justified in withdrawing the deduction claim under section 80IA(2A), and both legal grounds and case merits supported dismissal of the Revenue's appeal.
Note: It is a system-generated summary and is for quick reference only.