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...
Addition on account of capital gain - conversion of AOP/trust in company - transfer of the assets u/s 2(47) - till the time of conversion, the AOP remained in existence and the moment conversion took place, the company came into existence - the AOP and company never remained in existence simultaneously - transfer of a capital asset u/s 45(1) is possible only when there is a transferor and the transferee - no capital gain
Addition on account of capital gain - conversion of AOP/trust in company - transfer of the assets u/s 2(47) - till the time of conversion, the AOP remained in existence and the moment conversion took place, the company came into existence - the AOP and company never remained in existence simultaneously - transfer of a capital asset u/s 45(1) is possible only when there is a transferor and the transferee - no capital gain
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
