Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Rectification u/s 154 - Exemption u/s 11(2) - Accumulation of income - The Appellate Tribunal found merit in the appellant's contention regarding the amount to be accumulated under section 11(2) of the Act. - It was established that the appellant had accumulated Rs. 110,94,73,718/- in the specified modes under section 11(5) of the Act, which was lower than the required accumulation of Rs. 120,00,31,900/-. - Therefore, the deduction under section 11(2) was allowable only on the amount accumulated, resulting in a partial allowance of the claim.
Rectification u/s 154 - Exemption u/s 11(2) - Accumulation of income - The Appellate Tribunal found merit in the appellant's contention regarding the amount to be accumulated under section 11(2) of the Act. - It was established that the appellant had accumulated Rs. 110,94,73,718/- in the specified modes under section 11(5) of the Act, which was lower than the required accumulation of Rs. 120,00,31,900/-. - Therefore, the deduction under section 11(2) was allowable only on the amount accumulated, resulting in a partial allowance of the claim.
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TaxTMI 
TaxTMI 
of 4884 
