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...
The dominant issue was whether the percentage completion method under s. 43CB applies to real-estate business for estimating business profit, thereby sustaining additions toward estimated business income and deemed rental income. The appellate authority held that s. 43CB mandatorily applies to real-estate projects and, following binding precedent, rejected the taxpayer's contention that the provision was inapplicable; consequently, the additions made under s. 43CB were confirmed. As no material was produced to rebut these findings, the tribunal declined to interfere and dismissed the appeal. - ITAT
The dominant issue was whether the percentage completion method under s. 43CB applies to real-estate business for estimating business profit, thereby sustaining additions toward estimated business income and deemed rental income. The appellate authority held that s. 43CB mandatorily applies to real-estate projects and, following binding precedent, rejected the taxpayer's contention that the provision was inapplicable; consequently, the additions made under s. 43CB were confirmed. As no material was produced to rebut these findings, the tribunal declined to interfere and dismissed the appeal. - ITAT
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