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...
ITAT held that assessments under Section 153A were time-barred due to improper information exchange request. The tribunal relied on jurisdictional HC ruling which determined that references not complying with Indo-Swiss DTAA protocol's Article 14 cannot extend assessment limitation period. Specifically, requests made after 30/08/2010 violating the amending protocol's provisions were deemed invalid. Consequently, all challenged assessment orders and consequential penalty orders were set aside, affirming strict adherence to statutory limitation timelines and procedural requirements for international information exchange mechanisms.
ITAT held that assessments under Section 153A were time-barred due to improper information exchange request. The tribunal relied on jurisdictional HC ruling which determined that references not complying with Indo-Swiss DTAA protocol's Article 14 cannot extend assessment limitation period. Specifically, requests made after 30/08/2010 violating the amending protocol's provisions were deemed invalid. Consequently, all challenged assessment orders and consequential penalty orders were set aside, affirming strict adherence to statutory limitation timelines and procedural requirements for international information exchange mechanisms.
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