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...
In the absence of any agreement, arrangement or understanding showing that AMP expenditure was incurred for the associated enterprise's sole benefit, Chapter X could not be invoked and the transfer pricing adjustment on AMP spend was deleted. The Tribunal treated the section 14A grounds as consequential and accepted them accordingly. It also allowed the ground on computation-sheet mistakes and directed the Assessing Officer to correct the computation errors in accordance with law.
In the absence of any agreement, arrangement or understanding showing that AMP expenditure was incurred for the associated enterprise's sole benefit, Chapter X could not be invoked and the transfer pricing adjustment on AMP spend was deleted. The Tribunal treated the section 14A grounds as consequential and accepted them accordingly. It also allowed the ground on computation-sheet mistakes and directed the Assessing Officer to correct the computation errors in accordance with law.
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