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...
Unexplained investment u/s 69 - surrender of income - provisions u/s 115BBE - no set off of loss u/s 69 - CBDT has clarified that, the Board is of the view that since the term 'or set off of any loss' was specifically inserted only vide the Finance Act 2016, w.e.f. 01.04.2017, an assessee is entitled to claim set-off of loss against income determined under Section 115BBE of the Act till the assessment year 2016-17. - Since, CBDT Circular was issued after the order of the CIT(A), the CIT(A) did not have the benefit of the circular - Matter remanded back - AT
Unexplained investment u/s 69 - surrender of income - provisions u/s 115BBE - no set off of loss u/s 69 - CBDT has clarified that, the Board is of the view that since the term 'or set off of any loss' was specifically inserted only vide the Finance Act 2016, w.e.f. 01.04.2017, an assessee is entitled to claim set-off of loss against income determined under Section 115BBE of the Act till the assessment year 2016-17. - Since, CBDT Circular was issued after the order of the CIT(A), the CIT(A) did not have the benefit of the circular - Matter remanded back - AT
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