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 adjudicated multiple issues involving tax assessment for the assessee. Key determinations included: (1) upholding addition under Section 69C for undisclosed project expenditure based on matching accounting figures, (2) disallowing depreciation on gym equipment not installed at business premises, (3) accepting cancellation of property sale agreement and refund of advance, (4) allowing rent expenses for business premises despite procedural oversight, (5) validating foreign travel expenses for legitimate business purpose of marble procurement, and (6) deleting deemed profit additions and advance receipt additions due to lack of substantive evidence. Overall, most grounds were decided either partially or fully in favor of the assessee, with the tribunal emphasizing substantive compliance over procedural technicalities.
The ITAT adjudicated multiple issues involving tax assessment for the assessee. Key determinations included: (1) upholding addition under Section 69C for undisclosed project expenditure based on matching accounting figures, (2) disallowing depreciation on gym equipment not installed at business premises, (3) accepting cancellation of property sale agreement and refund of advance, (4) allowing rent expenses for business premises despite procedural oversight, (5) validating foreign travel expenses for legitimate business purpose of marble procurement, and (6) deleting deemed profit additions and advance receipt additions due to lack of substantive evidence. Overall, most grounds were decided either partially or fully in favor of the assessee, with the tribunal emphasizing substantive compliance over procedural technicalities.
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