Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
A co-operative bank's TDS position on interest paid to co-operative society depositors was traced to the CBDT Explanatory Note, not the proviso inserted in section 194A(3); the Court treated the Note as binding on the Department and held that the proviso only curtailed the broader exemption available to other co-operative societies. The proviso's constitutional challenge failed because exemption from TDS is a matter of legislative policy and section 80P is only a deduction provision, not a full tax exemption. The challenge based on administrative burden also failed, and protection was sustained for non-deduction done in obedience to subsisting interim orders.
A co-operative bank's TDS position on interest paid to co-operative society depositors was traced to the CBDT Explanatory Note, not the proviso inserted in section 194A(3); the Court treated the Note as binding on the Department and held that the proviso only curtailed the broader exemption available to other co-operative societies. The proviso's constitutional challenge failed because exemption from TDS is a matter of legislative policy and section 80P is only a deduction provision, not a full tax exemption. The challenge based on administrative burden also failed, and protection was sustained for non-deduction done in obedience to subsisting interim orders.
Note: It is a system-generated summary and is for quick reference only.
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