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...
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Nature of receipts - interest earned on FDs during the year was prior to commencement of business - The Appellate Tribunal referred to a previous decision involving the assessee for assessment years 2013-14 and 2014-15, wherein the ITAT Ahmedabad Bench ruled in favor of treating interest income earned on FDs before the commencement of business as capital receipts. Based on this precedent, the Tribunal upheld the decision to treat the interest income as capital receipts. It dismissed the Department's objection regarding the nexus between borrowed funds and investments, deeming it irrelevant in light of previous assessments.
Nature of receipts - interest earned on FDs during the year was prior to commencement of business - The Appellate Tribunal referred to a previous decision involving the assessee for assessment years 2013-14 and 2014-15, wherein the ITAT Ahmedabad Bench ruled in favor of treating interest income earned on FDs before the commencement of business as capital receipts. Based on this precedent, the Tribunal upheld the decision to treat the interest income as capital receipts. It dismissed the Department's objection regarding the nexus between borrowed funds and investments, deeming it irrelevant in light of previous assessments.
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