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...
Addition u/s 68 - unexplained investment - CIT(A) looked into the matter from the angle of the provision of section 56(2)(viib) brought on the statute book by the Finance Act, 2012 w.e.f. 01.04.2013. He observed that the premium charged by the assessee has to be subjected to the provisions of section 56(2)(viib) read with Rule 11UA(1)(c)(b) and it is for the assessee to furnish reliable valuation determining such share premium from a qualified valuer. The same premium are to be brought to tax. The Ld. CIT(A) gave necessary direction to the Ld. AO in this regard. Nothing has been brought on record by the Revenue to enable us to take a different view. - AT
Addition u/s 68 - unexplained investment - CIT(A) looked into the matter from the angle of the provision of section 56(2)(viib) brought on the statute book by the Finance Act, 2012 w.e.f. 01.04.2013. He observed that the premium charged by the assessee has to be subjected to the provisions of section 56(2)(viib) read with Rule 11UA(1)(c)(b) and it is for the assessee to furnish reliable valuation determining such share premium from a qualified valuer. The same premium are to be brought to tax. The Ld. CIT(A) gave necessary direction to the Ld. AO in this regard. Nothing has been brought on record by the Revenue to enable us to take a different view. - AT
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