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...
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Recording of satisfaction in the assessment order is a mandatory pre-condition for initiating penalty under section 271D where the alleged violation concerns section 269SS. The Tribunal held that the additional legal ground could be examined on the existing record because it went to the root of the penalty validity. As the assessment order accepted the assessee's explanation for the cash deposits and did not record any satisfaction for penalty initiation, the penalty proceedings could not be sustained. The penalty order was quashed and the assessee's appeal was allowed.
Recording of satisfaction in the assessment order is a mandatory pre-condition for initiating penalty under section 271D where the alleged violation concerns section 269SS. The Tribunal held that the additional legal ground could be examined on the existing record because it went to the root of the penalty validity. As the assessment order accepted the assessee's explanation for the cash deposits and did not record any satisfaction for penalty initiation, the penalty proceedings could not be sustained. The penalty order was quashed and the assessee's appeal was allowed.
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