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.69A for cash deposits was challenged on the ground that the deposits were explained by debtor collections and past savings/opening balance, a factual explanation allegedly not properly examined by the AO/CIT(A). The matter was remitted to the AO for fresh verification on merits and decision in accordance with law. Separately, penalty under s.271B was upheld because the obligation to get accounts audited under s.44AB is independent of the obligation to maintain books under s.44AA, and levy of penalty under s.271A is not a precondition for penalty under s.271B; absence of audit justified confirmation of penalty. - ITAT
Addition under s.69A for cash deposits was challenged on the ground that the deposits were explained by debtor collections and past savings/opening balance, a factual explanation allegedly not properly examined by the AO/CIT(A). The matter was remitted to the AO for fresh verification on merits and decision in accordance with law. Separately, penalty under s.271B was upheld because the obligation to get accounts audited under s.44AB is independent of the obligation to maintain books under s.44AA, and levy of penalty under s.271A is not a precondition for penalty under s.271B; absence of audit justified confirmation of penalty. - ITAT
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