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...
Section 87A, as applicable for the relevant assessment year, did not exclude tax on short-term capital gains taxable under section 111A. Although section 112A expressly limits the rebate for specified long-term capital gains, no equivalent restriction applied to section 111A income; the special tax rate governs tax computation but does not curtail the independent rebate absent express legislation. A later amendment restricting the rebate to tax computed under section 115BAC(1A), effective from Assessment Year 2026-27, cannot deny the benefit for Assessment Year 2024-25 without express retrospective operation. The notes state that rebate was to be granted and tax recomputed accordingly.
Section 87A, as applicable for the relevant assessment year, did not exclude tax on short-term capital gains taxable under section 111A. Although section 112A expressly limits the rebate for specified long-term capital gains, no equivalent restriction applied to section 111A income; the special tax rate governs tax computation but does not curtail the independent rebate absent express legislation. A later amendment restricting the rebate to tax computed under section 115BAC(1A), effective from Assessment Year 2026-27, cannot deny the benefit for Assessment Year 2024-25 without express retrospective operation. The notes state that rebate was to be granted and tax recomputed accordingly.
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