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...
Penalty u/s 271(1)(c) - defective notice u/s 274 - The Tribunal emphasized the necessity for such notices to clearly delineate the charge against the assessee, allowing them to prepare an adequate defense. It found that the AO's notices were deficient in this respect, not specifying whether the penalties were for "concealment of income" or "furnishing of inaccurate particulars of income." This ambiguity, the Tribunal held, constituted a failure to meet legal standards, rendering the penalties unsustainable.
Penalty u/s 271(1)(c) - defective notice u/s 274 - The Tribunal emphasized the necessity for such notices to clearly delineate the charge against the assessee, allowing them to prepare an adequate defense. It found that the AO's notices were deficient in this respect, not specifying whether the penalties were for "concealment of income" or "furnishing of inaccurate particulars of income." This ambiguity, the Tribunal held, constituted a failure to meet legal standards, rendering the penalties unsustainable.
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