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 held that the assessee successfully discharged the onus of establishing purchase genuineness by providing comprehensive documentary evidence including invoices, goods receipt notes, transport bills, and weighing bridge slips. Despite some procedural discrepancies and non-response to section 133(6) notices by certain parties, the tribunal affirmed that these factors do not automatically render transactions as bogus. The CIT(A)'s deletion of additions was upheld, and the revenue's appeal was dismissed, reinforcing the principle that mere procedural irregularities cannot invalidate legitimate business transactions when substantive evidence supports their authenticity.
ITAT held that the assessee successfully discharged the onus of establishing purchase genuineness by providing comprehensive documentary evidence including invoices, goods receipt notes, transport bills, and weighing bridge slips. Despite some procedural discrepancies and non-response to section 133(6) notices by certain parties, the tribunal affirmed that these factors do not automatically render transactions as bogus. The CIT(A)'s deletion of additions was upheld, and the revenue's appeal was dismissed, reinforcing the principle that mere procedural irregularities cannot invalidate legitimate business transactions when substantive evidence supports their authenticity.
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