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...
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
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