Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.
Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.
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