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 invalidated reassessment proceedings initiated under s.147 for AY 2014-15. AO's reliance solely on insight portal information regarding transactions with ASE Capital Markets Ltd was deemed mechanical and without independent application of mind. The assessee had fully disclosed F&O losses of Rs.41,56,218 in original return, accepted under s.143(3). AO failed to explain why only Rs.27,61,650 was considered non-genuine. No tangible material or verification supported the reopening, and AO's belief was based on borrowed satisfaction without considering existing assessment records. Court found no failure by assessee to disclose material facts, making reopening after four years unjustified as it merely reflected change of opinion.
HC invalidated reassessment proceedings initiated under s.147 for AY 2014-15. AO's reliance solely on insight portal information regarding transactions with ASE Capital Markets Ltd was deemed mechanical and without independent application of mind. The assessee had fully disclosed F&O losses of Rs.41,56,218 in original return, accepted under s.143(3). AO failed to explain why only Rs.27,61,650 was considered non-genuine. No tangible material or verification supported the reopening, and AO's belief was based on borrowed satisfaction without considering existing assessment records. Court found no failure by assessee to disclose material facts, making reopening after four years unjustified as it merely reflected change of opinion.
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