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...
In reassessment proceedings under s.147, issuance of notice under s.143(2) was held not mandatory where no return was filed in response to notice under s.148; the challenge to reassessment on this ground was rejected. Professional fees were held not taxable on accrual where the assessee consistently followed cash basis and the amounts, though reflected in Form 26AS with TDS, were not actually received during the relevant year; the addition was directed to be deleted. Deduction under Chapter VIA was directed to be allowed since it had been accepted in original and reassessment proceedings and supporting evidence was on record. - ITAT
In reassessment proceedings under s.147, issuance of notice under s.143(2) was held not mandatory where no return was filed in response to notice under s.148; the challenge to reassessment on this ground was rejected. Professional fees were held not taxable on accrual where the assessee consistently followed cash basis and the amounts, though reflected in Form 26AS with TDS, were not actually received during the relevant year; the addition was directed to be deleted. Deduction under Chapter VIA was directed to be allowed since it had been accepted in original and reassessment proceedings and supporting evidence was on record. - ITAT
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