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...
Under the project completion method, only costs that directly bring inventory to its present location and condition may be included in work-in-progress. Expenditure on advertisement, business promotion and commission to agents was treated as promotional and general business outgoings, so it remained revenue expenditure in the year incurred and could not be loaded into project cost merely because revenue had not yet been recognised. By contrast, loan processing charges and security expenses were found to be project-specific and directly connected with the project, so they had to be capitalised as part of work-in-progress.
Under the project completion method, only costs that directly bring inventory to its present location and condition may be included in work-in-progress. Expenditure on advertisement, business promotion and commission to agents was treated as promotional and general business outgoings, so it remained revenue expenditure in the year incurred and could not be loaded into project cost merely because revenue had not yet been recognised. By contrast, loan processing charges and security expenses were found to be project-specific and directly connected with the project, so they had to be capitalised as part of work-in-progress.
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