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...
Penalty u/s 271(1)(c) - deduction under Section 80P - Tribunal has recorded a finding of the fact that there is no evidence of concealment of income. Tribunal has concluded that the appellant had made a legitimate claim for exemption under section 80P(2)(a)(i) which was purely a legal in nature and even on rejection of such a claim, no penalty is leviable. - order of ITAT does not suffer from any legal infirmity. - HC
Penalty u/s 271(1)(c) - deduction under Section 80P - Tribunal has recorded a finding of the fact that there is no evidence of concealment of income. Tribunal has concluded that the appellant had made a legitimate claim for exemption under section 80P(2)(a)(i) which was purely a legal in nature and even on rejection of such a claim, no penalty is leviable. - order of ITAT does not suffer from any legal infirmity. - HC
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TaxTMI 
TaxTMI 
of 4918 
