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...
TDS under s. 194C is attracted at the earlier of credit or payment. Since the liability for external development charges arose on credit in AY 2012-13, any default under s. 201(1) and interest under s. 201(1A) could be fastened only for AY 2012-13; the assessee could not be treated as an assessee-in-default for AY 2014-15 for the same amounts. Further, applying s. 201(3), the limitation ran from the relevant credit event, and the last date to pass an order was 31-03-2019; the order dated 25-03-2021 was time-barred and was set aside. - ITAT
TDS under s. 194C is attracted at the earlier of credit or payment. Since the liability for external development charges arose on credit in AY 2012-13, any default under s. 201(1) and interest under s. 201(1A) could be fastened only for AY 2012-13; the assessee could not be treated as an assessee-in-default for AY 2014-15 for the same amounts. Further, applying s. 201(3), the limitation ran from the relevant credit event, and the last date to pass an order was 31-03-2019; the order dated 25-03-2021 was time-barred and was set aside. - ITAT
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