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. 69 for cash deposits during the demonetisation period was disputed on the ground that the deposits were already covered by additional income disclosed and taxed pursuant to settlement. The settlement order under s. 245D(4) recorded telescoping of cash balances of the assessee and a related trust against the additional income offered for earlier years, and the AO failed to show that such undisclosed income had been deployed elsewhere or that any outside-the-books investments existed. Applying the rule against double taxation of the same income and extending telescoping, the cash deposits were held explained out of previously taxed income, and no separate addition was sustainable; the Revenue's appeal was dismissed - ITAT
Addition under s. 69 for cash deposits during the demonetisation period was disputed on the ground that the deposits were already covered by additional income disclosed and taxed pursuant to settlement. The settlement order under s. 245D(4) recorded telescoping of cash balances of the assessee and a related trust against the additional income offered for earlier years, and the AO failed to show that such undisclosed income had been deployed elsewhere or that any outside-the-books investments existed. Applying the rule against double taxation of the same income and extending telescoping, the cash deposits were held explained out of previously taxed income, and no separate addition was sustainable; the Revenue's appeal was dismissed - ITAT
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