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 exemption u/s 10(46) was incorrect - petitioner was not systematically indulging in commercial activities with profit motive - loans extended were not for commercial purposes but to fulfil developmental objectives - investments in bonds, shares, and fixed deposits had direct connection with assigned role under UPID Act - petitioner acts as agent of Government for planned development, not a profit-oriented corporation - extending loans was directed by State Government, not motivated by profit intent - financial statements show negative income-expenditure margin, negating commercial assumption - HC quashed order, directed processing of exemption application u/s 10(46) in light of observations.
Denial of exemption u/s 10(46) was incorrect - petitioner was not systematically indulging in commercial activities with profit motive - loans extended were not for commercial purposes but to fulfil developmental objectives - investments in bonds, shares, and fixed deposits had direct connection with assigned role under UPID Act - petitioner acts as agent of Government for planned development, not a profit-oriented corporation - extending loans was directed by State Government, not motivated by profit intent - financial statements show negative income-expenditure margin, negating commercial assumption - HC quashed order, directed processing of exemption application u/s 10(46) in light of observations.
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