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 upholds that the impugned addition under assessment proceedings is unsustainable. The assessee demonstrated that the disputed receipts arose from GST invoices dated 12.4.2018 and 12.5.2018, declared in GSTR-1 and reflected in an updated Form 26AS, with corresponding tax deducted at source by the payer in FY 2017-18 (AY 2018-19). The Tribunal finds the receipts were correctly offered to tax in AY 2019-20, are revenue-neutral vis-Ã -vis matching TDS, and do not pertain to the assessment year under challenge. Consequently the addition is deleted and the assessee's appeal against the AO's assessment is allowed.
ITAT upholds that the impugned addition under assessment proceedings is unsustainable. The assessee demonstrated that the disputed receipts arose from GST invoices dated 12.4.2018 and 12.5.2018, declared in GSTR-1 and reflected in an updated Form 26AS, with corresponding tax deducted at source by the payer in FY 2017-18 (AY 2018-19). The Tribunal finds the receipts were correctly offered to tax in AY 2019-20, are revenue-neutral vis-Ã -vis matching TDS, and do not pertain to the assessment year under challenge. Consequently the addition is deleted and the assessee's appeal against the AO's assessment is allowed.
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