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...
Deduction u/s 36(1)(viii) - Whether assessee is eligible for deduction u/s 36(1)(viii) even though the assessee is not an eligible entity under the provisions of the Act prior to amendment w.e.f. 01.04.2008? - the assessee is squarely covered within the meaning of expression ‘Financial Corporation’ and is entitled to benefit of deduction under Section 36(1)(viii) of the Act. - HC
Deduction u/s 36(1)(viii) - Whether assessee is eligible for deduction u/s 36(1)(viii) even though the assessee is not an eligible entity under the provisions of the Act prior to amendment w.e.f. 01.04.2008? - the assessee is squarely covered within the meaning of expression ‘Financial Corporation’ and is entitled to benefit of deduction under Section 36(1)(viii) of the Act. - HC
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