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...
Exemption u/s 10(23C)(iiiad) - Threshold limit of Rs. 1 Crore - The Appellate Tribunal found that the appellant's gross receipts, when considering certain fee receipts from the previous financial year separately, did not exceed the threshold limit of Rs. 1 crore. Citing a precedent and interpreting the relevant provisions, the Tribunal held that each educational institution operated by the appellant should be treated as a separate entity for the purpose of determining eligibility for exemption. Therefore, the Tribunal concluded that the appellant was entitled to exemption under section 10(23C)(iiiad) of the Act.
Exemption u/s 10(23C)(iiiad) - Threshold limit of Rs. 1 Crore - The Appellate Tribunal found that the appellant's gross receipts, when considering certain fee receipts from the previous financial year separately, did not exceed the threshold limit of Rs. 1 crore. Citing a precedent and interpreting the relevant provisions, the Tribunal held that each educational institution operated by the appellant should be treated as a separate entity for the purpose of determining eligibility for exemption. Therefore, the Tribunal concluded that the appellant was entitled to exemption under section 10(23C)(iiiad) of the Act.
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