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...
HC dismissed petition challenging penalty proceedings under s271DA. AO initiated proceedings via reference to Addl. CIT within 11 days of assessment order completion (08.04.2024), following assessment order dated 28.03.2024. Six-month limitation period commenced from reference date. Court held timing reasonable, rejecting petitioner's argument of arbitrary extension. While acknowledging that inordinate delays require scrutiny and reasonable timeframe applies where no specific limitation exists, HC found 11-day gap between assessment completion and penalty initiation well within acceptable bounds. Proceedings deemed within limitation period prescribed under s275(1)(c).
HC dismissed petition challenging penalty proceedings under s271DA. AO initiated proceedings via reference to Addl. CIT within 11 days of assessment order completion (08.04.2024), following assessment order dated 28.03.2024. Six-month limitation period commenced from reference date. Court held timing reasonable, rejecting petitioner's argument of arbitrary extension. While acknowledging that inordinate delays require scrutiny and reasonable timeframe applies where no specific limitation exists, HC found 11-day gap between assessment completion and penalty initiation well within acceptable bounds. Proceedings deemed within limitation period prescribed under s275(1)(c).
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