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...
For squared up loans, the surviving cash credit addition under section 68 was set aside for fresh adjudication because the assessee had now produced creditor confirmations and sought an effective opportunity, while the earlier record was found incomplete on identity, creditworthiness and genuineness. For three non-squared up loan creditors, the addition was deleted because the assessee had filed primary evidence such as returns, balance sheets, bank statements and confirmations, the creditors responded to notices, and the Revenue failed to rebut that evidence with cogent material; suspicion could not replace proof. The related interest disallowance was held to be consequential and was directed to be recomputed in line with the final treatment of the loan additions.
For squared up loans, the surviving cash credit addition under section 68 was set aside for fresh adjudication because the assessee had now produced creditor confirmations and sought an effective opportunity, while the earlier record was found incomplete on identity, creditworthiness and genuineness. For three non-squared up loan creditors, the addition was deleted because the assessee had filed primary evidence such as returns, balance sheets, bank statements and confirmations, the creditors responded to notices, and the Revenue failed to rebut that evidence with cogent material; suspicion could not replace proof. The related interest disallowance was held to be consequential and was directed to be recomputed in line with the final treatment of the loan additions.
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