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...
Interest on enhanced compensation for compulsorily acquired agricultural land is taxable under the provisions governing such interest where binding jurisdictional precedent so requires. Rectification is limited to mistakes apparent from the record and cannot be used to review, modify, or avoid binding jurisdictional precedent on the basis of a contrary Coordinate Bench view; relief through rectification is therefore unavailable. Where the interest is taxable as income from other sources, the statutory fifty per cent deduction must be allowed. Taxable interest must consequently be computed after granting that deduction where it has not already been provided.
Interest on enhanced compensation for compulsorily acquired agricultural land is taxable under the provisions governing such interest where binding jurisdictional precedent so requires. Rectification is limited to mistakes apparent from the record and cannot be used to review, modify, or avoid binding jurisdictional precedent on the basis of a contrary Coordinate Bench view; relief through rectification is therefore unavailable. Where the interest is taxable as income from other sources, the statutory fifty per cent deduction must be allowed. Taxable interest must consequently be computed after granting that deduction where it has not already been provided.
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