Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
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...
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
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