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 allowed the appeal of the assessee, holding forex derivative losses were bona fide hedging business losses, not speculative, and directed their allowance; an ad-hoc 1% stock discrepancy addition was deleted. The DRP's fresh disallowance raised a new issue not examined by the AO and was held ultra vires; the DRP exceeded its jurisdiction by introducing a new source of income. Transfer pricing adjustments were restricted to LIBOR-based interest on loans to AEs, following coordinate-bench precedent. The Tribunal held notional interest on delayed receivables was not an international transaction for the relevant years and disallowed corresponding TP adjustment. The AO was directed to compute notional commission on a corporate guarantee at 1% interest.
The ITAT allowed the appeal of the assessee, holding forex derivative losses were bona fide hedging business losses, not speculative, and directed their allowance; an ad-hoc 1% stock discrepancy addition was deleted. The DRP's fresh disallowance raised a new issue not examined by the AO and was held ultra vires; the DRP exceeded its jurisdiction by introducing a new source of income. Transfer pricing adjustments were restricted to LIBOR-based interest on loans to AEs, following coordinate-bench precedent. The Tribunal held notional interest on delayed receivables was not an international transaction for the relevant years and disallowed corresponding TP adjustment. The AO was directed to compute notional commission on a corporate guarantee at 1% interest.
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