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...
Partial denial of exemption for benefit to specified persons was confined to the income said to have been diverted; the broader exemption under sections 11 and 12 was not forfeited in full, and the 15 per cent amount treated as deemed application under section 11 was deleted. A payment to a related concern was not hit by the specified concern rule because the trustee's voting power was below the 20 per cent threshold, and a procedural error in Form 10B did not defeat the exemption claim. Capital expenditure was also allowed as application of income on an accrual basis, with supporting invoices, disclosure in the balance sheet, and replies to notices sufficient on the facts.
Partial denial of exemption for benefit to specified persons was confined to the income said to have been diverted; the broader exemption under sections 11 and 12 was not forfeited in full, and the 15 per cent amount treated as deemed application under section 11 was deleted. A payment to a related concern was not hit by the specified concern rule because the trustee's voting power was below the 20 per cent threshold, and a procedural error in Form 10B did not defeat the exemption claim. Capital expenditure was also allowed as application of income on an accrual basis, with supporting invoices, disclosure in the balance sheet, and replies to notices sufficient on the facts.
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TaxTMI 
TaxTMI 
of 4918 
