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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Denial of deduction claimed under Chapter VI-A i.e. Section 80G/ 80GGA read with Section 35AC - The Appellate Tribunal noted that the appellant had not claimed the benefit of Sections 11 and 12 of the Act, as reflected in the AO's intimation order under Section 143(1) of the Act. Therefore, the appellant was entitled to deduction under Section 80GGA of the Act. Considering the appellant's consistent claims for deduction under Section 80GGA since Assessment Year 1993-94, and the absence of contrary evidence presented by the Revenue, the Tribunal upheld the appellant's entitlement to the deduction.
Denial of deduction claimed under Chapter VI-A i.e. Section 80G/ 80GGA read with Section 35AC - The Appellate Tribunal noted that the appellant had not claimed the benefit of Sections 11 and 12 of the Act, as reflected in the AO's intimation order under Section 143(1) of the Act. Therefore, the appellant was entitled to deduction under Section 80GGA of the Act. Considering the appellant's consistent claims for deduction under Section 80GGA since Assessment Year 1993-94, and the absence of contrary evidence presented by the Revenue, the Tribunal upheld the appellant's entitlement to the deduction.
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