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...
Section 263 revision turns on the distinction between lack of enquiry and inadequate enquiry. The Tribunal held that revision was justified where the AO had not specifically verified reversal of provision for onerous contract, but any tax on the reversal depends on whether the original provision was earlier allowed, to avoid double taxation; the matter was remitted for factual verification. For bad debts, the Tribunal held that a written-off debt satisfies section 36(1)(vii) and that revisional jurisdiction could not be used to demand further proof of irrecoverability. It also accepted evidence of buy-back tax payment and remitted Ind AS 116 lease adjustment claims for fresh examination under the Act independently of accounting standards.
Section 263 revision turns on the distinction between lack of enquiry and inadequate enquiry. The Tribunal held that revision was justified where the AO had not specifically verified reversal of provision for onerous contract, but any tax on the reversal depends on whether the original provision was earlier allowed, to avoid double taxation; the matter was remitted for factual verification. For bad debts, the Tribunal held that a written-off debt satisfies section 36(1)(vii) and that revisional jurisdiction could not be used to demand further proof of irrecoverability. It also accepted evidence of buy-back tax payment and remitted Ind AS 116 lease adjustment claims for fresh examination under the Act independently of accounting standards.
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