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 - addition u/s 50C - third proviso to Section 50C inserted w.e.f 1-4-2019 - benefit of variation of 5% - even when the statute does not specifically state so the insertion of third proviso to Section 50C is declaratory and curative in nature, can only be treated as retrospective and effective from the date related statutory provisions was introduced i.e. from 1st April 2003 - retrospective
Capital Gain - addition u/s 50C - third proviso to Section 50C inserted w.e.f 1-4-2019 - benefit of variation of 5% - even when the statute does not specifically state so the insertion of third proviso to Section 50C is declaratory and curative in nature, can only be treated as retrospective and effective from the date related statutory provisions was introduced i.e. from 1st April 2003 - retrospective
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