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 CIT(A)'s deletion of additions u/s 68 and 69A made on the basis of a seized day-cash-book/diary belonging to a third-party group. It held that unilateral decoding of notings by the AO, without examining the author or any connected person and without corroboration from bank records, audited books, confirmations or other primary evidence, lacked evidentiary value. As the loose sheets neither named the assessee nor established a one-to-one nexus with recorded cheque transactions, they were treated as "dumb documents." Additions based on such unverified third-party loose papers were held unsustainable, and the appeals were decided in favour of the assessee.
ITAT upheld the CIT(A)'s deletion of additions u/s 68 and 69A made on the basis of a seized day-cash-book/diary belonging to a third-party group. It held that unilateral decoding of notings by the AO, without examining the author or any connected person and without corroboration from bank records, audited books, confirmations or other primary evidence, lacked evidentiary value. As the loose sheets neither named the assessee nor established a one-to-one nexus with recorded cheque transactions, they were treated as "dumb documents." Additions based on such unverified third-party loose papers were held unsustainable, and the appeals were decided in favour of the assessee.
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