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...
Deduction u/s 10 B - The AO argued that the units were formed by the transfer of previously used machinery, disqualifying them from certain deductions. - The tribunal, however, noted that the CIT(A) had provided a detailed examination of the history and operations of these units, establishing that they were indeed new undertakings that satisfied the statutory requirements for the deduction under Section 10B. - One of the significant issues was whether the sales proceeds of exported goods were received in India within the prescribed time frame to qualify for exemptions under Section 10B. The tribunal found that despite minor discrepancies in documentation, the majority of proceeds were indeed received within the permissible period, thus supporting the assessee's claim for deduction.
Deduction u/s 10 B - The AO argued that the units were formed by the transfer of previously used machinery, disqualifying them from certain deductions. - The tribunal, however, noted that the CIT(A) had provided a detailed examination of the history and operations of these units, establishing that they were indeed new undertakings that satisfied the statutory requirements for the deduction under Section 10B. - One of the significant issues was whether the sales proceeds of exported goods were received in India within the prescribed time frame to qualify for exemptions under Section 10B. The tribunal found that despite minor discrepancies in documentation, the majority of proceeds were indeed received within the permissible period, thus supporting the assessee's claim for deduction.
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