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 penalty proceedings under Sections 271D, 271DA, and 271E cannot proceed without the Assessing Officer's recorded satisfaction regarding contraventions of Sections 269SS, 269ST, or 269T. The absence of explicit satisfaction notes in assessment orders renders consequential penalty proceedings invalid. The court granted respondents an opportunity to produce relevant records or file an affidavit-in-opposition disclosing additional material within two weeks, thereby preserving the potential for future penalty proceedings subject to proper documentation of statutory contraventions.
HC held that penalty proceedings under Sections 271D, 271DA, and 271E cannot proceed without the Assessing Officer's recorded satisfaction regarding contraventions of Sections 269SS, 269ST, or 269T. The absence of explicit satisfaction notes in assessment orders renders consequential penalty proceedings invalid. The court granted respondents an opportunity to produce relevant records or file an affidavit-in-opposition disclosing additional material within two weeks, thereby preserving the potential for future penalty proceedings subject to proper documentation of statutory contraventions.
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