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...
Denial of opportunity to test third-party evidence by cross-examination breaches natural justice and, where additions rest solely on uncorroborated seized material and a general statement not specifically identifying the taxpayer, such material cannot discharge the Revenue's onus to prove undisclosed consideration; accordingly the addition was unsustainable and deleted. The analysis emphasises that reliance on third-party search material requires both specific linkage to the taxpayer and procedural fairness through disclosure and the right to confront the witness; absent corroboration, the material only raises suspicion and does not justify tax additions.
Denial of opportunity to test third-party evidence by cross-examination breaches natural justice and, where additions rest solely on uncorroborated seized material and a general statement not specifically identifying the taxpayer, such material cannot discharge the Revenue's onus to prove undisclosed consideration; accordingly the addition was unsustainable and deleted. The analysis emphasises that reliance on third-party search material requires both specific linkage to the taxpayer and procedural fairness through disclosure and the right to confront the witness; absent corroboration, the material only raises suspicion and does not justify tax additions.
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