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 seized material and search statements did not conclusively establish falsification of entries or bogus purchase invoices, though accounting deficiencies justified rejection of books under s.145. It upheld the CIT(A)'s best judgment assessment under s.144, sustaining estimation of business profits at 10% of turnover, following industry comparables and the Empee Distilleries precedent. ITAT further ruled that, once income is estimated, separate disallowances (including data centre expenses and addition on sale of scrap) and additions under s.68 are impermissible, all deductions being subsumed in the profit estimate. Disallowance of CSR expenditure was also deleted as no deduction had been claimed. The Revenue's appeal was accordingly dismissed.
ITAT held that seized material and search statements did not conclusively establish falsification of entries or bogus purchase invoices, though accounting deficiencies justified rejection of books under s.145. It upheld the CIT(A)'s best judgment assessment under s.144, sustaining estimation of business profits at 10% of turnover, following industry comparables and the Empee Distilleries precedent. ITAT further ruled that, once income is estimated, separate disallowances (including data centre expenses and addition on sale of scrap) and additions under s.68 are impermissible, all deductions being subsumed in the profit estimate. Disallowance of CSR expenditure was also deleted as no deduction had been claimed. The Revenue's appeal was accordingly dismissed.
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