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...
The case involved denial of exemption u/s 11 due to late filing of return. The department argued return must be filed u/s 139(1) to claim exemption u/s 11. An amendment clarified return should be filed within time u/s 139. ITAT held the amendment excluded updated returns u/s 139(8) and all other returns were eligible. Assessee filed within time u/s 139(4), so exemption u/s 11 should not be denied. Circular clarified return must be filed within time u/s 139. ITAT relied on precedent that if return is filed before due date u/s 139(4), exemption u/s 11 cannot be denied. Department was directed to allow exemption u/s 11.
The case involved denial of exemption u/s 11 due to late filing of return. The department argued return must be filed u/s 139(1) to claim exemption u/s 11. An amendment clarified return should be filed within time u/s 139. ITAT held the amendment excluded updated returns u/s 139(8) and all other returns were eligible. Assessee filed within time u/s 139(4), so exemption u/s 11 should not be denied. Circular clarified return must be filed within time u/s 139. ITAT relied on precedent that if return is filed before due date u/s 139(4), exemption u/s 11 cannot be denied. Department was directed to allow exemption u/s 11.
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TaxTMI 
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