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 allowed admission of additional documentary evidence concerning intra-group services and interest on outstanding receivables, finding the materials go to the root of the controversy and require examination by the AO. The Tribunal declined to remit the matter to the DRP, holding the DRP functus officio after issuing directions under s.144C(5) and not a proper appellate forum for remand. The Tribunal set aside the final assessment and restored the matter to the AO for fresh adjudication of the transfer pricing adjustment and interest, directing the AO to verify the newly admitted evidence, afford the assessee opportunity of hearing, and pass a fresh order in accordance with law. Appeal allowed for statistical purposes.
The ITAT allowed admission of additional documentary evidence concerning intra-group services and interest on outstanding receivables, finding the materials go to the root of the controversy and require examination by the AO. The Tribunal declined to remit the matter to the DRP, holding the DRP functus officio after issuing directions under s.144C(5) and not a proper appellate forum for remand. The Tribunal set aside the final assessment and restored the matter to the AO for fresh adjudication of the transfer pricing adjustment and interest, directing the AO to verify the newly admitted evidence, afford the assessee opportunity of hearing, and pass a fresh order in accordance with law. Appeal allowed for statistical purposes.
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