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...
Validity of assessment u/s 153C - Presumption - Scope of documents belongs to assessee - ven if the draft financials were provided by the assessee to the searched entity, the said documents continued to be ‘belonged to’ the assessee, as the services of the searched entity were sought only for the purpose of finalising the accounts and if at all anything can be said to be belonging to the searched entity, it can only be the final outcome of such exercise, for which searched entity’s services were availed. - Contentions of the assessee rejected - AT
Validity of assessment u/s 153C - Presumption - Scope of documents belongs to assessee - ven if the draft financials were provided by the assessee to the searched entity, the said documents continued to be ‘belonged to’ the assessee, as the services of the searched entity were sought only for the purpose of finalising the accounts and if at all anything can be said to be belonging to the searched entity, it can only be the final outcome of such exercise, for which searched entity’s services were availed. - Contentions of the assessee rejected - AT
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