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...
LTCG - land including factory building of the assessee was acquired by the State Govt. and the assessee had received compensation including interest - As also settled law that the Income-tax authorities are bound by the guidelines laid down the CBDT Circulars. The position as it stands now with the passage of the RFCTLARR Act, is that all compensations received qua this Act are not taxable. It has been clarified by the CBDT Vide Circular No.36/2016 dated 21.10.2016 that even where there is no separate deduction allowable under the Income Tax Act, any compensation covered by sections 105 and 106 of the RFCTLARR Act is exempt from taxation. - AT
LTCG - land including factory building of the assessee was acquired by the State Govt. and the assessee had received compensation including interest - As also settled law that the Income-tax authorities are bound by the guidelines laid down the CBDT Circulars. The position as it stands now with the passage of the RFCTLARR Act, is that all compensations received qua this Act are not taxable. It has been clarified by the CBDT Vide Circular No.36/2016 dated 21.10.2016 that even where there is no separate deduction allowable under the Income Tax Act, any compensation covered by sections 105 and 106 of the RFCTLARR Act is exempt from taxation. - AT
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