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...
Capital gain - cost of acquisition of assets when partnership succeeded to company - Section 49 amended after filing of return - a new tax liability cannot be created by a subsequent amendment in respect of a transaction as well as the return of income filed when such law was not in the Statute book - cost of acquisition will be the value at which assets was booked at time of succession not the cost incurred by partnership firm
Capital gain - cost of acquisition of assets when partnership succeeded to company - Section 49 amended after filing of return - a new tax liability cannot be created by a subsequent amendment in respect of a transaction as well as the return of income filed when such law was not in the Statute book - cost of acquisition will be the value at which assets was booked at time of succession not the cost incurred by partnership firm
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