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...
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
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