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...
In an abated search assessment under section 153A, the return filed in response to the search notice substituted the earlier return, so the assessee could make a fresh or altered claim and the Revenue could not apply reassessment principles; the lease rentals from the IT park/SEZ were accepted as business income in line with the CBDT circular and past departmental acceptance. On disallowance under section 14A, the Tribunal sustained restriction of the disallowance under normal provisions to exempt income and upheld that section 14A read with Rule 8D could not be mechanically applied for book profit computation, subject to direct expenditure. The notional annual letting value of unsold stock-in-trade was deleted because section 23(5) operated only prospectively from assessment year 2018-19.
In an abated search assessment under section 153A, the return filed in response to the search notice substituted the earlier return, so the assessee could make a fresh or altered claim and the Revenue could not apply reassessment principles; the lease rentals from the IT park/SEZ were accepted as business income in line with the CBDT circular and past departmental acceptance. On disallowance under section 14A, the Tribunal sustained restriction of the disallowance under normal provisions to exempt income and upheld that section 14A read with Rule 8D could not be mechanically applied for book profit computation, subject to direct expenditure. The notional annual letting value of unsold stock-in-trade was deleted because section 23(5) operated only prospectively from assessment year 2018-19.
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