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...
Assessee failed to establish eligibility for immunity under section 270AA(3) because no application in Form 68-online or manual-was produced or acknowledged; alleged technical glitch was unsubstantiated. The reasoning applies the requirement that an immunity application must be filed and evidenced, and that absence of Form 68 or acknowledgment supports a finding of under reporting. Consequent to these factual and evidentiary findings, penalty liability under section 270A was sustained and the appeal was dismissed.
Assessee failed to establish eligibility for immunity under section 270AA(3) because no application in Form 68-online or manual-was produced or acknowledged; alleged technical glitch was unsubstantiated. The reasoning applies the requirement that an immunity application must be filed and evidenced, and that absence of Form 68 or acknowledgment supports a finding of under reporting. Consequent to these factual and evidentiary findings, penalty liability under section 270A was sustained and the appeal was dismissed.
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