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...
Proceedings u/s. 153C r.w.s. 153A - Recording of satisfaction - CIT (Appeals) not given finding that what basis he came to such conclusion that there was a recording of satisfaction by the Assessing Officer of searched person. We are of the opinion that recording of satisfaction is legal issue which shall be examined by the learned CIT (Appeals) after calling the relevant record from the AO of searched person and decide the issue afresh. - AT
Proceedings u/s. 153C r.w.s. 153A - Recording of satisfaction - CIT (Appeals) not given finding that what basis he came to such conclusion that there was a recording of satisfaction by the Assessing Officer of searched person. We are of the opinion that recording of satisfaction is legal issue which shall be examined by the learned CIT (Appeals) after calling the relevant record from the AO of searched person and decide the issue afresh. - AT
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