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...
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
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