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 adjudicated two primary issues: (1) International transaction involving Standby Letter of Credit (SBLC) and (2) Deduction under Section 80G for charitable donation. In the SBLC matter, the Tribunal held that issuance of SBLC to Associated Enterprise can be subject to Arm's Length Price (ALP) tests, directing Assessing Officer to consider 0.5% rate instead of 1.3%. Regarding donation, the Tribunal restored the matter to Assessing Officer, providing opportunity to re-examine the receipt's authenticity and accounting period, with liberty to allow Section 80G deduction if the assessee satisfactorily demonstrates the trust's proper accounting of the donated funds.
ITAT adjudicated two primary issues: (1) International transaction involving Standby Letter of Credit (SBLC) and (2) Deduction under Section 80G for charitable donation. In the SBLC matter, the Tribunal held that issuance of SBLC to Associated Enterprise can be subject to Arm's Length Price (ALP) tests, directing Assessing Officer to consider 0.5% rate instead of 1.3%. Regarding donation, the Tribunal restored the matter to Assessing Officer, providing opportunity to re-examine the receipt's authenticity and accounting period, with liberty to allow Section 80G deduction if the assessee satisfactorily demonstrates the trust's proper accounting of the donated funds.
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