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 distinct NP rates applied to separate businesses: AO applied a uniform 8% NP rate to both iron-scrap and livestock sales without any intelligible differentia; books of account contained no pointed defects. Tribunal accepted CIT(A)'s reliance on comparable assessments showing NP rates of 0.15-0.23% for livestock turnover and held that differential cost structures warrant a lower NP rate for animal sales; consequently the 0.22% NP rate was applied to livestock/animal sales and the AO's uniform 8% determination was set aside - ITAT
Whether distinct NP rates applied to separate businesses: AO applied a uniform 8% NP rate to both iron-scrap and livestock sales without any intelligible differentia; books of account contained no pointed defects. Tribunal accepted CIT(A)'s reliance on comparable assessments showing NP rates of 0.15-0.23% for livestock turnover and held that differential cost structures warrant a lower NP rate for animal sales; consequently the 0.22% NP rate was applied to livestock/animal sales and the AO's uniform 8% determination was set aside - ITAT
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