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...
Discount/margins retained by stockists on distribution of goods were held not to be "commission or brokerage" because the arrangement was principal-to-principal: invoices evidenced outright sales with applicable indirect tax, stockists bore inventory risk, had limited regulatory-compliance controls only, and independently recorded purchases/sales and offered profits to tax; further, the payer received sale consideration and did not make any commission payment, hence no TDS obligation under s.194H and no default under ss.201/201(1A). ESOP taxation arose only on exercise/allotment under s.17(2)(vi) and not at mere grant, so no TDS under s.192 and the demand was deleted. Interest for delayed payment to MSME suppliers was treated as part of sale consideration (not "interest" u/s 2(28A)) and, with voluntary disallowance u/s 37(1), s.194A and consequential ss.201/201(1A) were held inapplicable. - ITAT
Discount/margins retained by stockists on distribution of goods were held not to be "commission or brokerage" because the arrangement was principal-to-principal: invoices evidenced outright sales with applicable indirect tax, stockists bore inventory risk, had limited regulatory-compliance controls only, and independently recorded purchases/sales and offered profits to tax; further, the payer received sale consideration and did not make any commission payment, hence no TDS obligation under s.194H and no default under ss.201/201(1A). ESOP taxation arose only on exercise/allotment under s.17(2)(vi) and not at mere grant, so no TDS under s.192 and the demand was deleted. Interest for delayed payment to MSME suppliers was treated as part of sale consideration (not "interest" u/s 2(28A)) and, with voluntary disallowance u/s 37(1), s.194A and consequential ss.201/201(1A) were held inapplicable. - ITAT
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