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 the second reassessment u/s 147, initiated by notice u/s 148 dated 20/03/2020 on the same material and issues already examined and accepted in the earlier reassessment order u/s 143(3) r.w.s. 147 dated 28/11/2019, to be invalid as a mere change of opinion, following the SC ruling in Kelvinator. No new tangible material or independent enquiry was found. Consequently, the reassessment proceedings and additions treating LTCG as bogus and taxing it as unexplained money u/s 69A r.w.s. 115BBE were quashed. On merits also, in light of SEBI's final report exonerating the scrip, exemption u/s 10(38) was upheld and Revenue's case failed.
ITAT held the second reassessment u/s 147, initiated by notice u/s 148 dated 20/03/2020 on the same material and issues already examined and accepted in the earlier reassessment order u/s 143(3) r.w.s. 147 dated 28/11/2019, to be invalid as a mere change of opinion, following the SC ruling in Kelvinator. No new tangible material or independent enquiry was found. Consequently, the reassessment proceedings and additions treating LTCG as bogus and taxing it as unexplained money u/s 69A r.w.s. 115BBE were quashed. On merits also, in light of SEBI's final report exonerating the scrip, exemption u/s 10(38) was upheld and Revenue's case failed.
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