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 advances/deposits written off under "administrative expenses" pursuant to a settlement with an associated party were allowable as revenue deduction under s.37(1) or as business loss under s.28, or were in substance capital outlay for acquisition of an MRI machine. The appellate authority had allowed the claim without examining whether any expenditure or business loss actually arose in the course of business, whether the assessee was in the business of advancing loans, whether there was any attempt to procure the alleged capital asset, and whether the timing and substance of successive agreements supported a genuine business transaction; it also relied on inapplicable precedents and did not consider the binding decision cited by the Revenue. The matter was remanded for fresh adjudication, and the Revenue's appeal was allowed for statistical purposes. - ITAT
The dominant issue was whether advances/deposits written off under "administrative expenses" pursuant to a settlement with an associated party were allowable as revenue deduction under s.37(1) or as business loss under s.28, or were in substance capital outlay for acquisition of an MRI machine. The appellate authority had allowed the claim without examining whether any expenditure or business loss actually arose in the course of business, whether the assessee was in the business of advancing loans, whether there was any attempt to procure the alleged capital asset, and whether the timing and substance of successive agreements supported a genuine business transaction; it also relied on inapplicable precedents and did not consider the binding decision cited by the Revenue. The matter was remanded for fresh adjudication, and the Revenue's appeal was allowed for statistical purposes. - ITAT
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