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...
Violation of principles of natural justice - The court observed that while the show-cause notice provided details for a personal hearing, including the date, time, and venue, the abbreviation 'N.A.' indicated that no such hearing was actually scheduled. The court referred to Section 75(4) of the said Act, emphasizing that an opportunity of hearing must be provided before reaching a decision under Section 73. It noted that since an adverse decision was anticipated against the petitioners, the proper officer was duty-bound to grant them a hearing, regardless of the absence of a written request.
Violation of principles of natural justice - The court observed that while the show-cause notice provided details for a personal hearing, including the date, time, and venue, the abbreviation 'N.A.' indicated that no such hearing was actually scheduled. The court referred to Section 75(4) of the said Act, emphasizing that an opportunity of hearing must be provided before reaching a decision under Section 73. It noted that since an adverse decision was anticipated against the petitioners, the proper officer was duty-bound to grant them a hearing, regardless of the absence of a written request.
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