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 of mistake u/s 154 - AO issued notice u/s 154 based on audit objections, adding waiver of principal amount and revising book profit. Tribunal dismissed Revenue's appeal citing tax effect. CIT (A) allowed assessee's appeal, quashing audit objection merged into CIT (A) order. Tribunal dismissed Revenue's Miscellaneous Application, stating appeal not due to audit objection acceptance. Case not falling under CBDT Circular No. 3/2018 exceptions. High Court = HC.
Rectification of mistake u/s 154 - AO issued notice u/s 154 based on audit objections, adding waiver of principal amount and revising book profit. Tribunal dismissed Revenue's appeal citing tax effect. CIT (A) allowed assessee's appeal, quashing audit objection merged into CIT (A) order. Tribunal dismissed Revenue's Miscellaneous Application, stating appeal not due to audit objection acceptance. Case not falling under CBDT Circular No. 3/2018 exceptions. High Court = HC.
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