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...
Whether the paper company is engaged in any tax evasion? - Income Tax Act has been amended by incorporating the provisions of PoEM, GAAR for bringing such transactions under the net of tax. However, the provisions are not applicable to the year under consideration. Therefore, we are of the view that until and unless there is any violation of the provisions of law, it cannot be alleged that the assessee by adopting the colourable device has diverted the profit. - As we have decided the issue that profit attributable to RFZC belongs to DRC companies, then the question of the colourable device used by the assessee for diverting its profit does not arise. - AT
Whether the paper company is engaged in any tax evasion? - Income Tax Act has been amended by incorporating the provisions of PoEM, GAAR for bringing such transactions under the net of tax. However, the provisions are not applicable to the year under consideration. Therefore, we are of the view that until and unless there is any violation of the provisions of law, it cannot be alleged that the assessee by adopting the colourable device has diverted the profit. - As we have decided the issue that profit attributable to RFZC belongs to DRC companies, then the question of the colourable device used by the assessee for diverting its profit does not arise. - AT
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