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...
Addressing disputed purchases and commission claims, the note holds that where sales and business are accepted, purchases cannot be treated as wholly non-existent and an addition should be limited to the profit element; accordingly purchases from two suppliers (where statutory notices were unserved) were estimated at the declared gross profit rate of 6.5% to account for possible embedded profit and price inflation. Separately, commission and brokerage payments were held allowable where primary documentary evidence (ledgers, bills, bank payments, TDS proof) was produced and no independent adverse material or enquiries proved the payments were sham, so full disallowance was not justified.
Addressing disputed purchases and commission claims, the note holds that where sales and business are accepted, purchases cannot be treated as wholly non-existent and an addition should be limited to the profit element; accordingly purchases from two suppliers (where statutory notices were unserved) were estimated at the declared gross profit rate of 6.5% to account for possible embedded profit and price inflation. Separately, commission and brokerage payments were held allowable where primary documentary evidence (ledgers, bills, bank payments, TDS proof) was produced and no independent adverse material or enquiries proved the payments were sham, so full disallowance was not justified.
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