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...
Revision u/s 263 - Deduction u/s 80P on interest received from Cooperative Bank - After considering the submissions and the relevant statutory provisions and precedents, the Appellate Tribunal upheld the Revision order passed by the PCIT under section 263. The Tribunal concluded that interest earned from investments made in any bank, including cooperative banks, is not deductible under section 80P(2)(d) of the Income Tax Act, in accordance with the decision of the Hon. Gujarat High Court in Katlary Kariyana case.
Revision u/s 263 - Deduction u/s 80P on interest received from Cooperative Bank - After considering the submissions and the relevant statutory provisions and precedents, the Appellate Tribunal upheld the Revision order passed by the PCIT under section 263. The Tribunal concluded that interest earned from investments made in any bank, including cooperative banks, is not deductible under section 80P(2)(d) of the Income Tax Act, in accordance with the decision of the Hon. Gujarat High Court in Katlary Kariyana case.
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