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...
The ITAT ruled that the AO's addition under section 68 and denial of exemption under section 10(38) were untenable. The Tribunal found that the AO relied merely on assumptions from an Investigation Wing report without direct evidence, while ignoring evidence furnished by the assessee. Since the purchase of shares in an earlier year was accepted by revenue, and the sale occurred through the Stock Exchange with consideration received via banking channels, the sale proceeds could not be considered unexplained cash credits under section 68. Additionally, the ITAT deleted the disallowance under section 14A, noting that the AO failed to establish that investments were made using interest-bearing funds, making administrative expenditure disallowance impermissible.
The ITAT ruled that the AO's addition under section 68 and denial of exemption under section 10(38) were untenable. The Tribunal found that the AO relied merely on assumptions from an Investigation Wing report without direct evidence, while ignoring evidence furnished by the assessee. Since the purchase of shares in an earlier year was accepted by revenue, and the sale occurred through the Stock Exchange with consideration received via banking channels, the sale proceeds could not be considered unexplained cash credits under section 68. Additionally, the ITAT deleted the disallowance under section 14A, noting that the AO failed to establish that investments were made using interest-bearing funds, making administrative expenditure disallowance impermissible.
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