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 held that the limitation period for issuing notice u/s 153C commences from the date of seizure of documents (30.06.2022), not the search date (10.11.2020). The petitioner, being a third party, can respond to the show cause notice dated 30.12.2024 and contest the proceedings in accordance with law. Despite prior settlement at IBS, the Department retains liberty to proceed if new material emerges. The court found no merit in the petitioner's limitation argument and dismissed the writ petitions, upholding the impugned notice and order.
HC held that the limitation period for issuing notice u/s 153C commences from the date of seizure of documents (30.06.2022), not the search date (10.11.2020). The petitioner, being a third party, can respond to the show cause notice dated 30.12.2024 and contest the proceedings in accordance with law. Despite prior settlement at IBS, the Department retains liberty to proceed if new material emerges. The court found no merit in the petitioner's limitation argument and dismissed the writ petitions, upholding the impugned notice and order.
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