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...
Monetary limit for filing appeals before High Court not breached for assessment years 2006-07 to 2010-11, appeals dismissed as not maintainable. For assessment years 2011-12 and 2012-13, tax effect exceeds monetary limit but fundamental issue regarding availability of exemption to Trust u/s 12AA already decided in Trust's favor, questions of law raised by revenue answered against revenue in Trust's favor.
Monetary limit for filing appeals before High Court not breached for assessment years 2006-07 to 2010-11, appeals dismissed as not maintainable. For assessment years 2011-12 and 2012-13, tax effect exceeds monetary limit but fundamental issue regarding availability of exemption to Trust u/s 12AA already decided in Trust's favor, questions of law raised by revenue answered against revenue in Trust's favor.
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