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 proceedings u/s 153C - The High Court held that loose sheets and diaries, without corroborative evidence, do not constitute "books of account" and hence cannot be solely relied upon for tax assessment purposes. Additionally, the process of centralizing cases without providing a reasonable opportunity for the assessee to object was found to be in violation of Section 127. The notice under Section 153C was deemed invalid because it did not meet the prerequisites for invoking this section.
Validity of proceedings u/s 153C - The High Court held that loose sheets and diaries, without corroborative evidence, do not constitute "books of account" and hence cannot be solely relied upon for tax assessment purposes. Additionally, the process of centralizing cases without providing a reasonable opportunity for the assessee to object was found to be in violation of Section 127. The notice under Section 153C was deemed invalid because it did not meet the prerequisites for invoking this section.
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