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...
Reassessment founded on additions and disallowances in later assessment years lacks a subsisting basis where appellate orders for those years delete or decide in the assessee's favour every issue relied upon for reopening. Although later assessment orders may initially constitute material for reopening, the reasons to believe that income escaped assessment cease once their foundation is removed. The reassessment notice and rejection of objections were quashed, while other challenges remained open and proceedings could revive if the Revenue succeeds in pending appeals on a foundational issue.
Reassessment founded on additions and disallowances in later assessment years lacks a subsisting basis where appellate orders for those years delete or decide in the assessee's favour every issue relied upon for reopening. Although later assessment orders may initially constitute material for reopening, the reasons to believe that income escaped assessment cease once their foundation is removed. The reassessment notice and rejection of objections were quashed, while other challenges remained open and proceedings could revive if the Revenue succeeds in pending appeals on a foundational issue.
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