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...
Set off of brought forward loss against Long Term Capital Gain (LTCG) - AO was of the view that since the LTCL no longer exist in books of account, it cannot be set off consequent to the scheme of arrangement - It has not been brought out on record that by reason of the restructuring the books and the order of the Hon’ble Kerala High Court, the assessee is precluded from utilizing the carryforward LTCL against set off of LTCG in future years as contemplated by section 74 of the Act. - AT
Set off of brought forward loss against Long Term Capital Gain (LTCG) - AO was of the view that since the LTCL no longer exist in books of account, it cannot be set off consequent to the scheme of arrangement - It has not been brought out on record that by reason of the restructuring the books and the order of the Hon’ble Kerala High Court, the assessee is precluded from utilizing the carryforward LTCL against set off of LTCG in future years as contemplated by section 74 of the Act. - AT
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