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 Revenue's legal contention that documents seized from a third party could be considered in proceedings under s.153A where the assessee was also a searched person, holding s.153C inapplicable to that extent and setting aside the CIT(A)'s exclusion of such documents. However, on merits the Tribunal dismissed Revenue's additions under s.69B for completed assessments where no incriminating material was seized from the assessee's premises, finding the AO relied solely on third-party papers and granting relief to the assessee. The Tribunal upheld deletion of disallowance under s.40A(2)(b) for lack of objective material and accepted the CIT(A)'s telescoping of land-investment additions, rejecting Revenue's broader challenge.
The ITAT allowed Revenue's legal contention that documents seized from a third party could be considered in proceedings under s.153A where the assessee was also a searched person, holding s.153C inapplicable to that extent and setting aside the CIT(A)'s exclusion of such documents. However, on merits the Tribunal dismissed Revenue's additions under s.69B for completed assessments where no incriminating material was seized from the assessee's premises, finding the AO relied solely on third-party papers and granting relief to the assessee. The Tribunal upheld deletion of disallowance under s.40A(2)(b) for lack of objective material and accepted the CIT(A)'s telescoping of land-investment additions, rejecting Revenue's broader challenge.
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