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...
Reopening of assessment u/s 147 - Failure to rely upon the decision of HC / SC at objection stage - We fail to understand why these decisions could not have been taken at this stage itself so that the AO, having regard to the law laid down by the courts and on the submissions made by petitioner, could have discharged the notice u/s 148 of the Act. There is no reason to postpone it to the assessment proceedings stage. - HC
Reopening of assessment u/s 147 - Failure to rely upon the decision of HC / SC at objection stage - We fail to understand why these decisions could not have been taken at this stage itself so that the AO, having regard to the law laid down by the courts and on the submissions made by petitioner, could have discharged the notice u/s 148 of the Act. There is no reason to postpone it to the assessment proceedings stage. - HC
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