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...
Reopening of assessment u/s 147 - Disallowance of CSR amount u/s 37(2) - reason to believe or suspect - tangible material to reopen - AO power to review not to be confused with the power to re-assess - The petitioner argued that the notice was based on a change of opinion and lacked fresh tangible material. They also contested the treatment of CSR expenses and claimed that their practice was lawful. The High Court ruled in favor of the petitioner, holding that the notice for reopening the assessment was invalid and unsustainable, and the treatment of CSR expenses was permissible under the law. - The Court agreed with the petitioner's contention that donations made to eligible trusts, even if funded by CSR, qualified for deduction under Section 80G of the Act
Reopening of assessment u/s 147 - Disallowance of CSR amount u/s 37(2) - reason to believe or suspect - tangible material to reopen - AO power to review not to be confused with the power to re-assess - The petitioner argued that the notice was based on a change of opinion and lacked fresh tangible material. They also contested the treatment of CSR expenses and claimed that their practice was lawful. The High Court ruled in favor of the petitioner, holding that the notice for reopening the assessment was invalid and unsustainable, and the treatment of CSR expenses was permissible under the law. - The Court agreed with the petitioner's contention that donations made to eligible trusts, even if funded by CSR, qualified for deduction under Section 80G of the Act
Note: It is a system-generated summary and is for quick reference only.