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 arose over a gratuity expense claimed where one transferred employee's gratuity liability was moved to a related concern. Tribunal reasoned that transferring the liability to the other concern constituted discharge of the assessee's obligation akin to actual payment, because the employee had rendered services to the assessee and the liability was validly shifted; accordingly the gratuity expense was allowable and the appeal was allowed by the ITAT.
Disallowance arose over a gratuity expense claimed where one transferred employee's gratuity liability was moved to a related concern. Tribunal reasoned that transferring the liability to the other concern constituted discharge of the assessee's obligation akin to actual payment, because the employee had rendered services to the assessee and the liability was validly shifted; accordingly the gratuity expense was allowable and the appeal was allowed by the ITAT.
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