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...
Nature of receipt - relinquishment of trusteeship - additions to the income of the trustees by way of excess consideration received for the sale of the rubber plantation - The High Court concluded that consideration received by trustees for the relinquishment of their trusteeship could not be treated as a capital receipt but should be regarded as income and taxed under the appropriate head. The court remanded the matter back to the tribunal to pass a fresh order in light of its findings.
Nature of receipt - relinquishment of trusteeship - additions to the income of the trustees by way of excess consideration received for the sale of the rubber plantation - The High Court concluded that consideration received by trustees for the relinquishment of their trusteeship could not be treated as a capital receipt but should be regarded as income and taxed under the appropriate head. The court remanded the matter back to the tribunal to pass a fresh order in light of its findings.
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