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...
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Set off of MAT credit u/s.115JAA - assessee being a company had filed its return of income in ITR-6 (i.e. prescribed form) under schedule for MAT credit (Schedule MATC), the assessee is precluded from filling up any figure as they are automatically picked from yet another schedule in the same ITR form - there is absolutely no scope for ignoring surcharge and education cess for the purpose of computing MAT credit u/s.115JAA of the Act. It is a well known fact that the ITR return form is a form prescribed by CBDT and the revenue is bound to follow the same. - AT
Set off of MAT credit u/s.115JAA - assessee being a company had filed its return of income in ITR-6 (i.e. prescribed form) under schedule for MAT credit (Schedule MATC), the assessee is precluded from filling up any figure as they are automatically picked from yet another schedule in the same ITR form - there is absolutely no scope for ignoring surcharge and education cess for the purpose of computing MAT credit u/s.115JAA of the Act. It is a well known fact that the ITR return form is a form prescribed by CBDT and the revenue is bound to follow the same. - AT
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