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...
Artificial capital gains loss - colourable device to evade tax - Allegation of transfer of agricultural land to LLP to generation artificial loss to set off with capital gain - LLP created after conversion of Limited Company into LLP - The capital losses said to have been incurred by the assessee are only notional and introduced artificially. Authorities below rightly disallowed the same. - AT
Artificial capital gains loss - colourable device to evade tax - Allegation of transfer of agricultural land to LLP to generation artificial loss to set off with capital gain - LLP created after conversion of Limited Company into LLP - The capital losses said to have been incurred by the assessee are only notional and introduced artificially. Authorities below rightly disallowed the same. - AT
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