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...
Rejection of application u/s 119(2)(b) for condoning the delay in filing the Form 10B - delay was about 1257 days - Exemption u/s 10(23C) - assessment of trust - The High Court noted that the petitioner had a history of timely compliance with filing returns and Form 10B for other assessment years. Considering this, the Court inferred that the failure to file for the relevant assessment year was likely due to human error. The Court referred to a similar case where delay due to oversight by the auditor was accepted as reasonable cause. Ultimately, the Court allowed the writ petition, quashing the order of the revenue authority and condoning the delay in filing Form 10B.
Rejection of application u/s 119(2)(b) for condoning the delay in filing the Form 10B - delay was about 1257 days - Exemption u/s 10(23C) - assessment of trust - The High Court noted that the petitioner had a history of timely compliance with filing returns and Form 10B for other assessment years. Considering this, the Court inferred that the failure to file for the relevant assessment year was likely due to human error. The Court referred to a similar case where delay due to oversight by the auditor was accepted as reasonable cause. Ultimately, the Court allowed the writ petition, quashing the order of the revenue authority and condoning the delay in filing Form 10B.
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TaxTMI 
TaxTMI 
of 4918 
