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...
The Tribunal held that the 10% tolerance band under the stamp valuation framework applies retrospectively as a curative measure, so no addition survived where the difference between agreement value and stamp duty value was only 2.3%. It also accepted that indexation of cost for flat allotment rights runs from the date of the agreement, since rights accrued on execution and not from the dates of later instalments, leading to deletion of the recomputed disallowance. For the unexplained investment issue, the Tribunal found factual verification was needed and remanded the matter to the Assessing Officer after granting adequate hearing.
The Tribunal held that the 10% tolerance band under the stamp valuation framework applies retrospectively as a curative measure, so no addition survived where the difference between agreement value and stamp duty value was only 2.3%. It also accepted that indexation of cost for flat allotment rights runs from the date of the agreement, since rights accrued on execution and not from the dates of later instalments, leading to deletion of the recomputed disallowance. For the unexplained investment issue, the Tribunal found factual verification was needed and remanded the matter to the Assessing Officer after granting adequate hearing.
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