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 upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
ITAT upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
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