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...
Protective additions made in the society's assessment were held unsustainable because substantially identical diary entries were treated in substantive assessments of the individuals; the adjudicating body applied the peak-credit approach to allocate amounts to each individual and set those amounts off against income they had declared in the survey year. Given that surrendered income was credited to avoid double taxation, the protective addition in the society's hands was deleted on the ground that the same receipts cannot be taxed twice.
Protective additions made in the society's assessment were held unsustainable because substantially identical diary entries were treated in substantive assessments of the individuals; the adjudicating body applied the peak-credit approach to allocate amounts to each individual and set those amounts off against income they had declared in the survey year. Given that surrendered income was credited to avoid double taxation, the protective addition in the society's hands was deleted on the ground that the same receipts cannot be taxed twice.
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