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...
Regular Approval u/s 80G(5) - The High Court found that while the respondents had the authority to extend the time limit, there was no valid reason provided for the differential treatment between existing and new trusts regarding Section 80G approval. The court noted that the classification lacked a rational nexus with the object sought to be achieved, rendering it arbitrary and unconstitutional. - The court held that the petitioners did not have an inherent right to claim further extensions of time, even if an initial extension was granted by the respondents. The extension of time was considered an act of benevolence rather than a creation of vested rights on the part of the petitioners.
Regular Approval u/s 80G(5) - The High Court found that while the respondents had the authority to extend the time limit, there was no valid reason provided for the differential treatment between existing and new trusts regarding Section 80G approval. The court noted that the classification lacked a rational nexus with the object sought to be achieved, rendering it arbitrary and unconstitutional. - The court held that the petitioners did not have an inherent right to claim further extensions of time, even if an initial extension was granted by the respondents. The extension of time was considered an act of benevolence rather than a creation of vested rights on the part of the petitioners.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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