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...
Reopening of assessment u/s 147 - reopening beyond the period of four years - Merely because while framing assessment for the subsequent year, the AO noticed certain irregularity in the claim by itself would not be sufficient to satisfy requirements of the proviso to Section 147 - It is possible that the specific angle of the depreciation earlier claimed to be set off against the income of the current year of the eligible business may not have been in the mind of the Assessing Officer. - Notice quashed - HC
Reopening of assessment u/s 147 - reopening beyond the period of four years - Merely because while framing assessment for the subsequent year, the AO noticed certain irregularity in the claim by itself would not be sufficient to satisfy requirements of the proviso to Section 147 - It is possible that the specific angle of the depreciation earlier claimed to be set off against the income of the current year of the eligible business may not have been in the mind of the Assessing Officer. - Notice quashed - HC
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