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 - The High Court observed that the reasons provided by the Assessing Officer for reopening the assessment did not establish a live link between the information received and the belief that income had escaped assessment. There was no clear allegation of failure to disclose material facts by the petitioner. The court concluded that the reassessment was merely based on a change of opinion by the Assessing Officer, which did not justify reopening the assessment. It highlighted that a reason to suspect is not the same as a reason to believe, and there must be a rational connection between the material and the belief of income escapement.
Reopening of assessment u/s 147 - The High Court observed that the reasons provided by the Assessing Officer for reopening the assessment did not establish a live link between the information received and the belief that income had escaped assessment. There was no clear allegation of failure to disclose material facts by the petitioner. The court concluded that the reassessment was merely based on a change of opinion by the Assessing Officer, which did not justify reopening the assessment. It highlighted that a reason to suspect is not the same as a reason to believe, and there must be a rational connection between the material and the belief of income escapement.
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