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...
Applicability of reduced treaty rate to dividends: the tribunal applied the IndiaUK DTAA's lower dividend rate, relying on a recent Bombay HC precedent, and directed DDT to be charged at 10% with refund of excess DDT paid. Levy of postassessment interest after an advance pricing agreement: the tribunal found the incremental income crystallised only on signing the APA and therefore advance tax could not reasonably be paid earlier; it directed deletion and refund of additional interest levied. Short grant of TDS credit: the assessing officer is directed to verify and grant TDS credit as claimed in the modified return under applicable law.
Applicability of reduced treaty rate to dividends: the tribunal applied the IndiaUK DTAA's lower dividend rate, relying on a recent Bombay HC precedent, and directed DDT to be charged at 10% with refund of excess DDT paid. Levy of postassessment interest after an advance pricing agreement: the tribunal found the incremental income crystallised only on signing the APA and therefore advance tax could not reasonably be paid earlier; it directed deletion and refund of additional interest levied. Short grant of TDS credit: the assessing officer is directed to verify and grant TDS credit as claimed in the modified return under applicable law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
