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...
Properties treated as proceeds of crime remained attachable where the appellants failed to prove acquisition from independent lawful sources or payment of consideration. The Appellate Tribunal found that the respondent had established the foundational case that the assets originally stood with M/s AGFVIL and were later transferred through intermediary, namesake transactions without supporting proof of genuine purchase. For one appellant, the record showed only a shifted name without documentary evidence of consideration; for another, alleged loans, seller payment, and bank trail were not substantiated; for the third, the later explanation of source was inconsistent with her own statement and unsupported by material. The confirmation of the provisional attachment was upheld.
Properties treated as proceeds of crime remained attachable where the appellants failed to prove acquisition from independent lawful sources or payment of consideration. The Appellate Tribunal found that the respondent had established the foundational case that the assets originally stood with M/s AGFVIL and were later transferred through intermediary, namesake transactions without supporting proof of genuine purchase. For one appellant, the record showed only a shifted name without documentary evidence of consideration; for another, alleged loans, seller payment, and bank trail were not substantiated; for the third, the later explanation of source was inconsistent with her own statement and unsupported by material. The confirmation of the provisional attachment was upheld.
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