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...
Transfer pricing adjustment - Interest on delayed debtors/outstanding receivables from the AE - the assessee is fallowing a consistency approach of equality by not charging any interest from its AEs and non AEs though the payment in exceptional cases received beyond the credit period. Accordingly, we direct the AO/TPO to exclude the charging of interest on delayed debtors in computing the ALP. - AT
Transfer pricing adjustment - Interest on delayed debtors/outstanding receivables from the AE - the assessee is fallowing a consistency approach of equality by not charging any interest from its AEs and non AEs though the payment in exceptional cases received beyond the credit period. Accordingly, we direct the AO/TPO to exclude the charging of interest on delayed debtors in computing the ALP. - AT
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