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...
Various disallowances and additions made by the Assessing Officer (AO) and the Income Tax Appellate Tribunal's (ITAT) decisions on the same. The key points are: 1) Disallowance u/s 40(a)(ia) for non-deduction of TDS on ocean freight charges was deleted, as per CBDT circular, neither Section 194C nor 195 is applicable to such payments. 2) Disallowance of entire traveling expenses was restricted to 25% as no proof of business purpose was provided. 3) Addition u/s 41(1) for outstanding sundry creditors was deleted as the amount was offered to tax in the subsequent year, avoiding double taxation. 4) Disallowance of motor car expenses and depreciation was restricted to 10% for personal use, following judicial precedents. 5) Disallowance of excess interest payment u/s 40A(2)(b) was deleted, relying on the Gujarat High Court decision.
Various disallowances and additions made by the Assessing Officer (AO) and the Income Tax Appellate Tribunal's (ITAT) decisions on the same. The key points are: 1) Disallowance u/s 40(a)(ia) for non-deduction of TDS on ocean freight charges was deleted, as per CBDT circular, neither Section 194C nor 195 is applicable to such payments. 2) Disallowance of entire traveling expenses was restricted to 25% as no proof of business purpose was provided. 3) Addition u/s 41(1) for outstanding sundry creditors was deleted as the amount was offered to tax in the subsequent year, avoiding double taxation. 4) Disallowance of motor car expenses and depreciation was restricted to 10% for personal use, following judicial precedents. 5) Disallowance of excess interest payment u/s 40A(2)(b) was deleted, relying on the Gujarat High Court decision.
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