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 clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
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