Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
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...
Addition under s. 68 for unsecured loans was held unsustainable where the assessee furnished confirmations/affidavits, bank statements showing availability of funds, and banking-channel transfers, thereby establishing identity, creditworthiness, and genuineness; the AO, despite having complete particulars, made no independent verification by issuing summons/notices under s. 133(6) and relied only on suspicion regarding low income or cash deposits, which could not substitute evidence, and the Finance Act, 2022 second proviso to s. 68 was held inapplicable to AY 2016-17; the addition was deleted. Ad hoc disallowance of expenses for want of vouchers was restricted from 20% to 5% as reasonable. - ITAT
Addition under s. 68 for unsecured loans was held unsustainable where the assessee furnished confirmations/affidavits, bank statements showing availability of funds, and banking-channel transfers, thereby establishing identity, creditworthiness, and genuineness; the AO, despite having complete particulars, made no independent verification by issuing summons/notices under s. 133(6) and relied only on suspicion regarding low income or cash deposits, which could not substitute evidence, and the Finance Act, 2022 second proviso to s. 68 was held inapplicable to AY 2016-17; the addition was deleted. Ad hoc disallowance of expenses for want of vouchers was restricted from 20% to 5% as reasonable. - ITAT
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