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...
Where an addition in assessment arose solely from an estimation of non-genuine purchases and the taxable profit element was computed on that estimate, the statutory threshold for levying a penalty for concealment or furnishing inaccurate particulars was not met. Precedents establish that estimate-based disallowances, made without concrete evidence of deliberate concealment, do not attract penalty liability. Applying that principle, the tribunal directed deletion of the penalty levied in respect of the assessment year because the impugned addition was founded on estimate and therefore did not justify a penalty.
Where an addition in assessment arose solely from an estimation of non-genuine purchases and the taxable profit element was computed on that estimate, the statutory threshold for levying a penalty for concealment or furnishing inaccurate particulars was not met. Precedents establish that estimate-based disallowances, made without concrete evidence of deliberate concealment, do not attract penalty liability. Applying that principle, the tribunal directed deletion of the penalty levied in respect of the assessment year because the impugned addition was founded on estimate and therefore did not justify a penalty.
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