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...
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
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