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...
Minimum Alternate Tax under section 115JB does not apply to a statutory body constituted under a Central enactment that is not incorporated under the Companies Act, despite being assessable as a company under the Income-tax Act. Applying the principle that the legal fiction in section 115JB cannot extend to such entities, the High Court found the provision inapplicable. Consequently, the issue of disallowance under section 14A in computing book profit did not survive, as it depended on section 115JB applying. No substantial question of law arose, and the Revenue's appeals were dismissed.
Minimum Alternate Tax under section 115JB does not apply to a statutory body constituted under a Central enactment that is not incorporated under the Companies Act, despite being assessable as a company under the Income-tax Act. Applying the principle that the legal fiction in section 115JB cannot extend to such entities, the High Court found the provision inapplicable. Consequently, the issue of disallowance under section 14A in computing book profit did not survive, as it depended on section 115JB applying. No substantial question of law arose, and the Revenue's appeals were dismissed.
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