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...
Recovery of refund granted erroneously - It is settled legal position that inordinate delay in adjudication results into denial of principles of natural justice. In the case in hand, the assessee cannot be blamed for delay as they had never delayed the proceedings. Adjudication proceedings have to be culminated within reasonable time and if not, it would be vitiated. The act on the part of Revenue of keeping the show cause notice pending for unduly long period is arbitrary and it would, in my opinion, vitiate the entire proceedings. - AT
Recovery of refund granted erroneously - It is settled legal position that inordinate delay in adjudication results into denial of principles of natural justice. In the case in hand, the assessee cannot be blamed for delay as they had never delayed the proceedings. Adjudication proceedings have to be culminated within reasonable time and if not, it would be vitiated. The act on the part of Revenue of keeping the show cause notice pending for unduly long period is arbitrary and it would, in my opinion, vitiate the entire proceedings. - AT
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