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 allowed the assessees' appeals and quashed the impugned assessments. It held that additions made in search assessments u/s 153A were unsustainable as they were not based on any incriminating material found during search; the sole basis was the statement of a third party, which is insufficient. The Tribunal further held that, assuming such statement could be relied upon, the correct provision would have been s.153C, not s.153A. Additionally, the common and mechanical approval u/s 153D for multiple years and assessees, without evidence of independent application of mind by the approving authority, rendered the assessments vitiated.
ITAT allowed the assessees' appeals and quashed the impugned assessments. It held that additions made in search assessments u/s 153A were unsustainable as they were not based on any incriminating material found during search; the sole basis was the statement of a third party, which is insufficient. The Tribunal further held that, assuming such statement could be relied upon, the correct provision would have been s.153C, not s.153A. Additionally, the common and mechanical approval u/s 153D for multiple years and assessees, without evidence of independent application of mind by the approving authority, rendered the assessments vitiated.
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