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...
Lease Agreement - Transfer of Property - Appellant argued that the clause in the lease agreement only applies to voluntary transfers, not to mergers or amalgamations - The Supreme Court interpreted the clause in the lease agreement broadly, finding that it covers both voluntary and involuntary transfers, including mergers. It noted that the clause's language did not exclude involuntary transfers, and thus, the amalgamation fell within its purview. - The Court affirmed that the amalgamation, despite being governed by company law, resulted in a transfer of properties from the transferor to the transferee company. - Thus, the dispute concerning the interpretation of the lease agreement clause in the context of the company amalgamation was resolved in favor of the DDA.
Lease Agreement - Transfer of Property - Appellant argued that the clause in the lease agreement only applies to voluntary transfers, not to mergers or amalgamations - The Supreme Court interpreted the clause in the lease agreement broadly, finding that it covers both voluntary and involuntary transfers, including mergers. It noted that the clause's language did not exclude involuntary transfers, and thus, the amalgamation fell within its purview. - The Court affirmed that the amalgamation, despite being governed by company law, resulted in a transfer of properties from the transferor to the transferee company. - Thus, the dispute concerning the interpretation of the lease agreement clause in the context of the company amalgamation was resolved in favor of the DDA.
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