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 where amounts received by an assessee firm are duly recorded in its books and partners affirm introduction of capital, an addition under s. 68 cannot be sustained against the firm; any doubt as to the creditworthiness or genuineness of the source must be investigated qua the individual partner who introduced the funds rather than against the firm. The tribunal concluded that treating partners' capital deployed for land acquisition as unexplained investment vis-Ã -vis the firm was impermissible. Accordingly, the assessing officer's addition was annulled, the appellate authority's contrary finding was set aside, and the firm's corresponding grounds were allowed.
ITAT held that where amounts received by an assessee firm are duly recorded in its books and partners affirm introduction of capital, an addition under s. 68 cannot be sustained against the firm; any doubt as to the creditworthiness or genuineness of the source must be investigated qua the individual partner who introduced the funds rather than against the firm. The tribunal concluded that treating partners' capital deployed for land acquisition as unexplained investment vis-Ã -vis the firm was impermissible. Accordingly, the assessing officer's addition was annulled, the appellate authority's contrary finding was set aside, and the firm's corresponding grounds were allowed.
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