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 reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
Validity of reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
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