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...
TPA - whether AO should have decided the issue of international transaction himself instead of referring it to Transfer Pricing Officer as the quantum of International Transaction is below the monetary limit of ₹ 5 crore? - If powers conferred on a particular authority are arrogated by other authority without mandate of law, it will create chaos in the administration of law and hierarchy of administration will mean nothing. Satisfaction of one authority cannot be substituted by the satisfaction of the other authority. - AT
TPA - whether AO should have decided the issue of international transaction himself instead of referring it to Transfer Pricing Officer as the quantum of International Transaction is below the monetary limit of ₹ 5 crore? - If powers conferred on a particular authority are arrogated by other authority without mandate of law, it will create chaos in the administration of law and hierarchy of administration will mean nothing. Satisfaction of one authority cannot be substituted by the satisfaction of the other authority. - AT
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