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...
The six-month application period for rectifying orders denying input tax credit was questioned as an impermissible restriction on statutory entitlement. Although the Government may prescribe a special procedure for input tax credit, that power must include conditions and safeguards protecting taxpayers. The amended provision made credit available for returns filed by the stipulated date but did not impose an application deadline. A procedure that bars relief after six months without allowing extension where sufficient cause prevented timely application curtails the accrued right to credit. The notification was considered deficient for lacking such a safeguard, with further consideration directed after impleadment of relevant governmental bodies.
The six-month application period for rectifying orders denying input tax credit was questioned as an impermissible restriction on statutory entitlement. Although the Government may prescribe a special procedure for input tax credit, that power must include conditions and safeguards protecting taxpayers. The amended provision made credit available for returns filed by the stipulated date but did not impose an application deadline. A procedure that bars relief after six months without allowing extension where sufficient cause prevented timely application curtails the accrued right to credit. The notification was considered deficient for lacking such a safeguard, with further consideration directed after impleadment of relevant governmental bodies.
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