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...
Minimum alternate Tax (MAT) - Tax credit u/s 115JAA - surcharge and cess - Revenue (CPC) has admittedly applied surcharge and education cess on a tax credit u/s. 115JAA i.e., at 9.062%, or at a higher than applicable rate of 8.15%, resulting in an additional charge. As it appears, the levy of surcharge/cess while allowing tax credit, has not been on the amount of credit, but on Rs. 259.07 lacs, the tax payable under the regular provisions of the Act. - Whatever may be the behavior of the surcharge and cess rates over the two years, there is, per the said manner of allowing credit, it may be appreciated, no breach of the principle of non-double levy and, besides, is consistent with s. 115JAA. - AT
Minimum alternate Tax (MAT) - Tax credit u/s 115JAA - surcharge and cess - Revenue (CPC) has admittedly applied surcharge and education cess on a tax credit u/s. 115JAA i.e., at 9.062%, or at a higher than applicable rate of 8.15%, resulting in an additional charge. As it appears, the levy of surcharge/cess while allowing tax credit, has not been on the amount of credit, but on Rs. 259.07 lacs, the tax payable under the regular provisions of the Act. - Whatever may be the behavior of the surcharge and cess rates over the two years, there is, per the said manner of allowing credit, it may be appreciated, no breach of the principle of non-double levy and, besides, is consistent with s. 115JAA. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
