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...
The ITAT held that the disallowance of exemption claimed u/s 10(23C)(vi) due to a clerical error in the income tax return was improper. The order u/s 154 by CPC violated natural justice by not allowing the assessee a hearing. The CIT(A) should have decided the appeal on merits. The ITAT set aside the CIT(A)'s order and remanded the matter for fresh adjudication. The CIT(A) must verify the exemption claim, grant relief if valid, and ensure the assessee's right to be heard before issuing a new order.
The ITAT held that the disallowance of exemption claimed u/s 10(23C)(vi) due to a clerical error in the income tax return was improper. The order u/s 154 by CPC violated natural justice by not allowing the assessee a hearing. The CIT(A) should have decided the appeal on merits. The ITAT set aside the CIT(A)'s order and remanded the matter for fresh adjudication. The CIT(A) must verify the exemption claim, grant relief if valid, and ensure the assessee's right to be heard before issuing a new order.
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TaxTMI 
TaxTMI 
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