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...
Validity of revision under assessment revision power was contested where AO allowed exemption for investment in venture capital undertakings; HC/ITAT found AO had applied mind after detailed enquiry, making PCITs substitution of opinion impermissible, and restored the assessment. Tribunal noted investments taxed in unit holders hands so revenue suffered no prejudice, SEBI VCF Regulations permit temporary mutual fund investments, and the VCF Regulations (post amendment) no longer exclude real estate, so investments in real estate VCUs did not breach regulatory eligibility for the exemption.
Validity of revision under assessment revision power was contested where AO allowed exemption for investment in venture capital undertakings; HC/ITAT found AO had applied mind after detailed enquiry, making PCITs substitution of opinion impermissible, and restored the assessment. Tribunal noted investments taxed in unit holders hands so revenue suffered no prejudice, SEBI VCF Regulations permit temporary mutual fund investments, and the VCF Regulations (post amendment) no longer exclude real estate, so investments in real estate VCUs did not breach regulatory eligibility for the exemption.
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