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...
Assessing Officer's suo motu computation of net profit based solely on a survey statement without rejecting books or affording explanation was held arbitrary and the addition deleted. Alleged deemed sales of four parking spaces lacked contemporaneous stock records; Tribunal remitted the matter for fresh verification and afforded the assessee a hearing. Interest on unsecured loans capitalised as part of Work in Progress for a real estate developer was treated as business expenditure (acquisition/holding of land as inventory) and the AO's disallowance of such capitalised interest was reversed.
Assessing Officer's suo motu computation of net profit based solely on a survey statement without rejecting books or affording explanation was held arbitrary and the addition deleted. Alleged deemed sales of four parking spaces lacked contemporaneous stock records; Tribunal remitted the matter for fresh verification and afforded the assessee a hearing. Interest on unsecured loans capitalised as part of Work in Progress for a real estate developer was treated as business expenditure (acquisition/holding of land as inventory) and the AO's disallowance of such capitalised interest was reversed.
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