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...
Penalty under section 271D could not be sustained because no satisfaction was recorded in the assessment order initiating penalty proceedings. The Tribunal held that where the returned income was accepted and no quantum addition was made, there was no occasion in the assessment order to record the requisite satisfaction, and the Assessing Officer could not validly proceed by issuing a separate show-cause notice and penalty order. Relying on binding precedent, the Tribunal treated the absence of recorded satisfaction as fatal to jurisdiction and allowed the assessee's appeal without examining the merits.
Penalty under section 271D could not be sustained because no satisfaction was recorded in the assessment order initiating penalty proceedings. The Tribunal held that where the returned income was accepted and no quantum addition was made, there was no occasion in the assessment order to record the requisite satisfaction, and the Assessing Officer could not validly proceed by issuing a separate show-cause notice and penalty order. Relying on binding precedent, the Tribunal treated the absence of recorded satisfaction as fatal to jurisdiction and allowed the assessee's appeal without examining the merits.
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