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...
Writ petition maintainable. Respondent-University qualifies as 'educational institution'. Income from specified educational services not taxable due to Negative List. Income from non-educational activities like building rent taxable unless exempt under notifications. Affiliation fees, penalties, fines not 'activity for consideration', hence not taxable. Exemption notifications applicable, not contrary to parent statute. Difference between Negative List and exemption notifications explained. University provides auxiliary educational services, eligible for exemption under relevant notifications.
Writ petition maintainable. Respondent-University qualifies as 'educational institution'. Income from specified educational services not taxable due to Negative List. Income from non-educational activities like building rent taxable unless exempt under notifications. Affiliation fees, penalties, fines not 'activity for consideration', hence not taxable. Exemption notifications applicable, not contrary to parent statute. Difference between Negative List and exemption notifications explained. University provides auxiliary educational services, eligible for exemption under relevant notifications.
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