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...
Disallowance under s.14A was unsustainable because the AO enhanced the disallowance despite the assessee's detailed working, without examining the accounts to record the mandatory dissatisfaction with the assessee's computation; deletion of the additional disallowance was upheld. Addition of the s.14A amount while computing book profit under s.115JB was impermissible in law, consistent with binding precedent that such disallowance cannot be mechanically added back; the MAT adjustment was deleted. Deduction under s.35(2AB) could not be denied merely for non-availability of DSIR Form 3CL during assessment when the form was subsequently issued and covered the relevant expenditure; the deduction was allowed. - ITAT
Disallowance under s.14A was unsustainable because the AO enhanced the disallowance despite the assessee's detailed working, without examining the accounts to record the mandatory dissatisfaction with the assessee's computation; deletion of the additional disallowance was upheld. Addition of the s.14A amount while computing book profit under s.115JB was impermissible in law, consistent with binding precedent that such disallowance cannot be mechanically added back; the MAT adjustment was deleted. Deduction under s.35(2AB) could not be denied merely for non-availability of DSIR Form 3CL during assessment when the form was subsequently issued and covered the relevant expenditure; the deduction was allowed. - ITAT
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