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...
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
