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...
Exemption u/s 11 - reasonableness of payment rent to school buildings and also computer hirings rents to the trustees - The rental agreements clearly mention that besides building other amenities like furniture, electrical fittings, parking and open ground was also used by the trust. AO is not correct in making comparison with the municipal valuation and the assessee has made excessive payment to the trustees. - AT
Exemption u/s 11 - reasonableness of payment rent to school buildings and also computer hirings rents to the trustees - The rental agreements clearly mention that besides building other amenities like furniture, electrical fittings, parking and open ground was also used by the trust. AO is not correct in making comparison with the municipal valuation and the assessee has made excessive payment to the trustees. - AT
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