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...
Year-end estimated expenditure provisions, where invoices, precise liabilities and payees remain unascertained, do not amount to credit of an ascertainable sum to an identified payee under the mercantile system. Tax-deduction obligations therefore arise only when liabilities crystallise, with tax deducted where applicable upon receipt of invoices; reversal of the provisions in the succeeding year supports that treatment. A demand for tax-deduction default cannot be sustained merely on creation of such provisions. Further, where the same non-deduction has already led to disallowance of expenditure, it cannot also support a tax-deduction default demand; consequential interest fails with the principal demand.
Year-end estimated expenditure provisions, where invoices, precise liabilities and payees remain unascertained, do not amount to credit of an ascertainable sum to an identified payee under the mercantile system. Tax-deduction obligations therefore arise only when liabilities crystallise, with tax deducted where applicable upon receipt of invoices; reversal of the provisions in the succeeding year supports that treatment. A demand for tax-deduction default cannot be sustained merely on creation of such provisions. Further, where the same non-deduction has already led to disallowance of expenditure, it cannot also support a tax-deduction default demand; consequential interest fails with the principal demand.
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