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...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
The ITAT deleted the addition for unexplained investment/purchases because the Revenue failed to produce material directly linking the assessee to the alleged unaccounted transactions with Tirth Gold. The Tribunal noted that the assessee had furnished ledger accounts, bank statement, GST registration certificate and a declaration from Tirth Gold stating that no sales were made to the assessee for the relevant assessment year, but these documents were overlooked. Reliance only on third-party statements and digital data, without corroboration identifying the assessee as involved in undisclosed purchases or investment, was insufficient to sustain the addition. The assessee's appeal was allowed.
The ITAT deleted the addition for unexplained investment/purchases because the Revenue failed to produce material directly linking the assessee to the alleged unaccounted transactions with Tirth Gold. The Tribunal noted that the assessee had furnished ledger accounts, bank statement, GST registration certificate and a declaration from Tirth Gold stating that no sales were made to the assessee for the relevant assessment year, but these documents were overlooked. Reliance only on third-party statements and digital data, without corroboration identifying the assessee as involved in undisclosed purchases or investment, was insufficient to sustain the addition. The assessee's appeal was allowed.
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