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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The ITAT considered the grant of registration u/s 12AB, where the assessee's application was rejected for non-compliance and failure to prove genuineness of activities. The company incorporated in 2021 filed for registration in 2022 with financial statements. The ITAT found the CIT(E)'s decision incorrect as the final accounts were filed. Donation and expenditure details were provided, supported by receipts and bills. The AO accepted the expenditure in a previous assessment. The ITAT concluded the assessee is engaged in charitable activities and deserves another opportunity to be heard by the CIT(E) for a fair decision. The appeal was allowed for statistical purposes.
The ITAT considered the grant of registration u/s 12AB, where the assessee's application was rejected for non-compliance and failure to prove genuineness of activities. The company incorporated in 2021 filed for registration in 2022 with financial statements. The ITAT found the CIT(E)'s decision incorrect as the final accounts were filed. Donation and expenditure details were provided, supported by receipts and bills. The AO accepted the expenditure in a previous assessment. The ITAT concluded the assessee is engaged in charitable activities and deserves another opportunity to be heard by the CIT(E) for a fair decision. The appeal was allowed for statistical purposes.
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