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 partly allowed revenue's appeal in tax assessment matter. Regarding addition under section 56(2)(x) for property valuation, ITAT upheld CIT(A)'s deletion following precedent where detailed valuation considered industrial NA land characteristics and stamp duty authority rules. For cash advance on Hundi, ITAT sustained CIT(A)'s deletion finding no evidence that Rs. 26 lakh exceeded documented Rs. 25 lakh loan paid through banking channels. However, ITAT reversed CIT(A) on interest receivable from advances, holding accrued interest must be added to total income since assessee admitted giving loan. For agricultural income classification, ITAT modified CIT(A)'s complete deletion, allowing Rs. 75,000 as reasonable agricultural income from 4.6 hectares but treating balance Rs. 1,01,015 as income from other sources due to insufficient cultivation proof.
ITAT partly allowed revenue's appeal in tax assessment matter. Regarding addition under section 56(2)(x) for property valuation, ITAT upheld CIT(A)'s deletion following precedent where detailed valuation considered industrial NA land characteristics and stamp duty authority rules. For cash advance on Hundi, ITAT sustained CIT(A)'s deletion finding no evidence that Rs. 26 lakh exceeded documented Rs. 25 lakh loan paid through banking channels. However, ITAT reversed CIT(A) on interest receivable from advances, holding accrued interest must be added to total income since assessee admitted giving loan. For agricultural income classification, ITAT modified CIT(A)'s complete deletion, allowing Rs. 75,000 as reasonable agricultural income from 4.6 hectares but treating balance Rs. 1,01,015 as income from other sources due to insufficient cultivation proof.
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