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...
Transactions between the assessee and its Indian dependent agent permanent establishments having been accepted at arm's length after transfer pricing proceedings, no further profit attribution to the PE was permissible under the treaty principle applied by the Tribunal, and the related addition was deleted. On the refund interest claim, the Tribunal did not decide the entitlement on merits and instead directed factual verification by the Assessing Officer in accordance with law, with disposal based on that verification.
Transactions between the assessee and its Indian dependent agent permanent establishments having been accepted at arm's length after transfer pricing proceedings, no further profit attribution to the PE was permissible under the treaty principle applied by the Tribunal, and the related addition was deleted. On the refund interest claim, the Tribunal did not decide the entitlement on merits and instead directed factual verification by the Assessing Officer in accordance with law, with disposal based on that verification.
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