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...
Form 10-IC filed within the applicable due date preserved the option for the concessional corporate tax regime, because the due date under section 139(1) depends on the assessee's class and is not advanced merely by belated filing of Form 3CEB or an incorrect return selection. The text notes that later furnishing of the transfer-pricing report before assessment did not justify denial of the option. Once the option under section 115BAA was validly exercised, tax had to be computed under that regime and MAT under section 115JB could not be applied.
Form 10-IC filed within the applicable due date preserved the option for the concessional corporate tax regime, because the due date under section 139(1) depends on the assessee's class and is not advanced merely by belated filing of Form 3CEB or an incorrect return selection. The text notes that later furnishing of the transfer-pricing report before assessment did not justify denial of the option. Once the option under section 115BAA was validly exercised, tax had to be computed under that regime and MAT under section 115JB could not be applied.
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