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 u/s 154 - The Assessee filed a rectification application, which was dismissed by the CIT(A) based on the assumption of Tribunal's adjudication on the issue. - The Appellate Tribunal concluded that the CIT(A) had erroneously assumed that the issue of unexplained cash was adjudicated upon by the Tribunal. The Tribunal emphasized that the Tribunal's decision focused solely on the jewellery aspect, without any discussion on the unexplained cash addition. - CIT(A) directed for fresh consideration.
Rectification u/s 154 - The Assessee filed a rectification application, which was dismissed by the CIT(A) based on the assumption of Tribunal's adjudication on the issue. - The Appellate Tribunal concluded that the CIT(A) had erroneously assumed that the issue of unexplained cash was adjudicated upon by the Tribunal. The Tribunal emphasized that the Tribunal's decision focused solely on the jewellery aspect, without any discussion on the unexplained cash addition. - CIT(A) directed for fresh consideration.
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