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 addressed differential turnover where assessee declared lower turnover compared to Form 26QB and audit report Form 3CA. AO added entire differential amount to total income. CIT(A) restricted addition to profit element at 15% of differential receipts. ITAT held that since assessee's P&L Account reflected net material consumption considering opening/closing work-in-progress, entire differential amount cannot constitute income. Given assessee's declared gross profit rate of 16.22%, ITAT modified CIT(A)'s order directing AO to compute income using 16.22% gross profit rate instead of 15%. Revenue's appeal partly allowed with profit computation adjusted to reflect assessee's actual gross profit margin rather than CIT(A)'s conservative estimate.
ITAT addressed differential turnover where assessee declared lower turnover compared to Form 26QB and audit report Form 3CA. AO added entire differential amount to total income. CIT(A) restricted addition to profit element at 15% of differential receipts. ITAT held that since assessee's P&L Account reflected net material consumption considering opening/closing work-in-progress, entire differential amount cannot constitute income. Given assessee's declared gross profit rate of 16.22%, ITAT modified CIT(A)'s order directing AO to compute income using 16.22% gross profit rate instead of 15%. Revenue's appeal partly allowed with profit computation adjusted to reflect assessee's actual gross profit margin rather than CIT(A)'s conservative estimate.
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