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...
Assessee, a non-resident Indian, did not file return of income for AY 2014-15 as TDS on interest income from investment was deducted at 12.5% instead of 10% under India-UAE DTAA. Assessment order lacked direction or satisfaction for penalty proceedings u/s 271(1)(c). Case neither involved concealment nor furnishing inaccurate particulars of income as declared income was accepted. Assessee's belief of proper TDS deduction based on legitimate expectation accepted. Penalty proceedings unsustainable under law. Point determined in favor of assessee against revenue.
Assessee, a non-resident Indian, did not file return of income for AY 2014-15 as TDS on interest income from investment was deducted at 12.5% instead of 10% under India-UAE DTAA. Assessment order lacked direction or satisfaction for penalty proceedings u/s 271(1)(c). Case neither involved concealment nor furnishing inaccurate particulars of income as declared income was accepted. Assessee's belief of proper TDS deduction based on legitimate expectation accepted. Penalty proceedings unsustainable under law. Point determined in favor of assessee against revenue.
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