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 - the registration was granted by the ld. CIT(E) on 18-05-2023 and the assessment proceedings got concluded, much before that, on 17-12-2019. - As such, the assessment year under consideration, namely, 2012-13, is not covered by the express mandate of the registration. - the assessee cannot claim the benefit of exemption u/s. 11 for the year under consideration in any manner. - AT
Exemption u/s 11 - the registration was granted by the ld. CIT(E) on 18-05-2023 and the assessment proceedings got concluded, much before that, on 17-12-2019. - As such, the assessment year under consideration, namely, 2012-13, is not covered by the express mandate of the registration. - the assessee cannot claim the benefit of exemption u/s. 11 for the year under consideration in any manner. - AT
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