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 search-linked reassessment under the post-01.04.2021 regime, a search, a post-assessment statement, and field verification were treated as fresh tangible material supporting a reasoned belief of escapement; the challenge based on change of opinion and absence of incriminating material was rejected. For the unexplained cash credit issue, the Tribunal found that the Revenue relied substantially on an adverse third-party statement that was uncorroborated, while the assessee was denied cross-examination, amounting to a serious breach of natural justice. It also noted that Section 68 applies only to credits received in the relevant year, not opening balances, and remitted the additions for fresh adjudication after cross-examination and proper inquiry.
In search-linked reassessment under the post-01.04.2021 regime, a search, a post-assessment statement, and field verification were treated as fresh tangible material supporting a reasoned belief of escapement; the challenge based on change of opinion and absence of incriminating material was rejected. For the unexplained cash credit issue, the Tribunal found that the Revenue relied substantially on an adverse third-party statement that was uncorroborated, while the assessee was denied cross-examination, amounting to a serious breach of natural justice. It also noted that Section 68 applies only to credits received in the relevant year, not opening balances, and remitted the additions for fresh adjudication after cross-examination and proper inquiry.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
