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...
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Exemption u/s 11 - benefit denied on delay in filling the audit report - The Appellate Tribunal acknowledged the delay in filing Form 10B but noted that the issue of denial of exemption solely on the grounds of this delay has been addressed in various judicial precedents. It cited the Gujarat High Court's decision in Sarvodaya Charitable Trust vs. ITO(E) and similar rulings by other benches. These rulings established that if a trust substantially satisfies the conditions for exemption under section 11, denial of exemption solely on the basis of a procedural delay is unjustified.
Exemption u/s 11 - benefit denied on delay in filling the audit report - The Appellate Tribunal acknowledged the delay in filing Form 10B but noted that the issue of denial of exemption solely on the grounds of this delay has been addressed in various judicial precedents. It cited the Gujarat High Court's decision in Sarvodaya Charitable Trust vs. ITO(E) and similar rulings by other benches. These rulings established that if a trust substantially satisfies the conditions for exemption under section 11, denial of exemption solely on the basis of a procedural delay is unjustified.
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