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...
Whether advertising expenditure is revenue or capital: applying statutory principles and binding precedent, the court rejected estoppel against the statute and held that characterization in books does not override tax law; relying on Supreme Court authority and Gujarat HC precedent, such advertisement outlays are not capitalizable but are revenue expenditures deductible under the Act. Consequence: the assessment treating the expenditure as capital was set aside and the appeal allowing deduction was allowed. - HC
Whether advertising expenditure is revenue or capital: applying statutory principles and binding precedent, the court rejected estoppel against the statute and held that characterization in books does not override tax law; relying on Supreme Court authority and Gujarat HC precedent, such advertisement outlays are not capitalizable but are revenue expenditures deductible under the Act. Consequence: the assessment treating the expenditure as capital was set aside and the appeal allowing deduction was allowed. - HC
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