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...
Penalty for misreporting under section 270A requires the revenue to identify and establish a statutory instance of misreporting. Transfer-pricing adjustments arising solely from rejection of the taxpayer's benchmarking methodology, economic or comparability analysis, and adoption of a different most appropriate method do not by themselves establish misreporting. Reporting international transactions in Form 3CEB and maintaining prescribed transfer-pricing documentation support the position that the transactions were disclosed. Where no failure to report an international transaction or other statutory misreporting circumstance is identified, the adjustment falls within the exclusion for eligible transfer-pricing adjustments and cannot attract misreporting penalty.
Penalty for misreporting under section 270A requires the revenue to identify and establish a statutory instance of misreporting. Transfer-pricing adjustments arising solely from rejection of the taxpayer's benchmarking methodology, economic or comparability analysis, and adoption of a different most appropriate method do not by themselves establish misreporting. Reporting international transactions in Form 3CEB and maintaining prescribed transfer-pricing documentation support the position that the transactions were disclosed. Where no failure to report an international transaction or other statutory misreporting circumstance is identified, the adjustment falls within the exclusion for eligible transfer-pricing adjustments and cannot attract misreporting penalty.
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