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...
Assessment u/s 153A - claim of deduction under section 80IA(4) - Paper company or not - assessee as a SPV was a mandatory requirement of NHAI - four laning of the existing road - to be considered as a new infrastructure facility or not - AO directed to verify the correctness of assessee's computation of deduction u/s 80IA and allow the same. Further, to ensure that deduction for the same infrastructure facility is not allowed to both the assessee and Gil, the Assessing Officer is directed to verify the relevant facts and thereafter compute deduction u/s 80IA. - AT
Assessment u/s 153A - claim of deduction under section 80IA(4) - Paper company or not - assessee as a SPV was a mandatory requirement of NHAI - four laning of the existing road - to be considered as a new infrastructure facility or not - AO directed to verify the correctness of assessee's computation of deduction u/s 80IA and allow the same. Further, to ensure that deduction for the same infrastructure facility is not allowed to both the assessee and Gil, the Assessing Officer is directed to verify the relevant facts and thereafter compute deduction u/s 80IA. - AT
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