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...
Reopening of assessment was invalidated for lack of tangible material and the AO's independent application of mind; the notice under section 147/148 rested on 'borrowed satisfaction' from the investigation wing without requisite nexus or reasoned inference of escapement and therefore failed the four essential ingredients for reopening. On merits, share application monies treated as unexplained cash credits under section 68 were deleted: the assessee produced confirmations, bank statements and investors' audited accounts and sought summonses, and the Tribunal found the evidentiary onus discharged despite limited third party noncompliance.
Reopening of assessment was invalidated for lack of tangible material and the AO's independent application of mind; the notice under section 147/148 rested on 'borrowed satisfaction' from the investigation wing without requisite nexus or reasoned inference of escapement and therefore failed the four essential ingredients for reopening. On merits, share application monies treated as unexplained cash credits under section 68 were deleted: the assessee produced confirmations, bank statements and investors' audited accounts and sought summonses, and the Tribunal found the evidentiary onus discharged despite limited third party noncompliance.
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