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...
Provisional attachment of a bank account under section 83 is a drastic power that can be exercised only on a prior, valid formation of opinion based on tangible material and after compliance with mandatory procedural safeguards. The pre-attachment communication and attachment order were vague, issued without a show cause notice, and disclosed no proper material or reasoning; the attachment therefore breached the petitioner's civil rights and was unlawful. The High Court quashed the attachment orders but permitted the authorities to proceed afresh in accordance with law if tangible material exists. Finding a gross abuse of power and high-handed conduct causing serious civil consequences, the Court also imposed personal costs on the concerned officer.
Provisional attachment of a bank account under section 83 is a drastic power that can be exercised only on a prior, valid formation of opinion based on tangible material and after compliance with mandatory procedural safeguards. The pre-attachment communication and attachment order were vague, issued without a show cause notice, and disclosed no proper material or reasoning; the attachment therefore breached the petitioner's civil rights and was unlawful. The High Court quashed the attachment orders but permitted the authorities to proceed afresh in accordance with law if tangible material exists. Finding a gross abuse of power and high-handed conduct causing serious civil consequences, the Court also imposed personal costs on the concerned officer.
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