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 Section 68 alleging unexplained share capital and share premium was contested on grounds of identity, creditworthiness and genuineness of subscribers; court accepted traceability via bank records and Section 133(6) responses, finding subscribers to be taxpayers and creditworthy, and therefore rejected characterization as phantom investors. The prospective proviso to Section 68 (Finance Act, 2012) was held inapplicable for the relevant assessment year, so the "source of source" and "origin of origin" doctrines were not applied. Allegations of money laundering or roundtripping lacked specific corroborative evidence showing a live link to the assessee; Tribunal findings for the assessee were upheld.
Addition under Section 68 alleging unexplained share capital and share premium was contested on grounds of identity, creditworthiness and genuineness of subscribers; court accepted traceability via bank records and Section 133(6) responses, finding subscribers to be taxpayers and creditworthy, and therefore rejected characterization as phantom investors. The prospective proviso to Section 68 (Finance Act, 2012) was held inapplicable for the relevant assessment year, so the "source of source" and "origin of origin" doctrines were not applied. Allegations of money laundering or roundtripping lacked specific corroborative evidence showing a live link to the assessee; Tribunal findings for the assessee were upheld.
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