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...
Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.
Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.
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