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 remanded matter to AO for verification of agricultural land's distance from GHMC municipal limits as of sale date 07.09.2007. Land constitutes capital asset under Section 2(14)(iii)(b) if within 8 km radius of notified municipality. Tribunal upheld CIT(A)'s allowance of Section 54F exemption but clarified investment deadline extends to delayed return filing date under Section 139(4), not merely due date. Section 54B exemption properly restricted to registered sale deed values, rejecting higher agreement amounts. Cost of improvement deduction denied due to insufficient substantiation beyond rough notebook entries. AO directed to allow investments made up to delayed return filing date and verify land distance for capital asset determination.
ITAT remanded matter to AO for verification of agricultural land's distance from GHMC municipal limits as of sale date 07.09.2007. Land constitutes capital asset under Section 2(14)(iii)(b) if within 8 km radius of notified municipality. Tribunal upheld CIT(A)'s allowance of Section 54F exemption but clarified investment deadline extends to delayed return filing date under Section 139(4), not merely due date. Section 54B exemption properly restricted to registered sale deed values, rejecting higher agreement amounts. Cost of improvement deduction denied due to insufficient substantiation beyond rough notebook entries. AO directed to allow investments made up to delayed return filing date and verify land distance for capital asset determination.
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