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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Charitable entity u/s 2(15) denied exemption u/ss 11 and 12 by Assessing Officer (AO) on grounds of conducting exhibitions being commercial in nature. ITAT held no markup on consideration charged from exporters, thus activity beyond purview of trade, commerce, business or services related thereto. Assessee not hit by proviso to section 2(15) for conducting exhibitions within India or overseas. AO directed to grant exemption u/ss 11 and 12. Regarding disallowance u/s 11(2) for not specifying objects for accumulation in Form 10, CIT(A) relying on Gujarat High Court and Supreme Court orders held lack of declaration not fatal. Board resolution accumulating surplus for specified purposes u/s 11(2) perused. Claim for prior period expenditure allowed by CIT(A) as expenditure incurred towards trust objects, upheld by ITAT.
Charitable entity u/s 2(15) denied exemption u/ss 11 and 12 by Assessing Officer (AO) on grounds of conducting exhibitions being commercial in nature. ITAT held no markup on consideration charged from exporters, thus activity beyond purview of trade, commerce, business or services related thereto. Assessee not hit by proviso to section 2(15) for conducting exhibitions within India or overseas. AO directed to grant exemption u/ss 11 and 12. Regarding disallowance u/s 11(2) for not specifying objects for accumulation in Form 10, CIT(A) relying on Gujarat High Court and Supreme Court orders held lack of declaration not fatal. Board resolution accumulating surplus for specified purposes u/s 11(2) perused. Claim for prior period expenditure allowed by CIT(A) as expenditure incurred towards trust objects, upheld by ITAT.
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