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...
Denial of exemption u/s 11 for assessment of a trust due to rejection of application for condonation of delay in filing Form 10B. The petitioner inadvertently delayed filing Form 10B due to the clerical staff of the Chartered Accountant suffering from a brain tumor. The High Court held that although the audit report was obtained on 07.05.2015, prior to the return filing date of 26.09.2015, the respondent adopted a pedantic approach in rejecting the condonation application. The reasons provided by the petitioner cannot be discarded as not constituting genuine hardship. The High Court quashed the impugned order, directing the respondent to condone the delay in filing Form 10B to enable the petitioner to obtain exemption u/s 11.
Denial of exemption u/s 11 for assessment of a trust due to rejection of application for condonation of delay in filing Form 10B. The petitioner inadvertently delayed filing Form 10B due to the clerical staff of the Chartered Accountant suffering from a brain tumor. The High Court held that although the audit report was obtained on 07.05.2015, prior to the return filing date of 26.09.2015, the respondent adopted a pedantic approach in rejecting the condonation application. The reasons provided by the petitioner cannot be discarded as not constituting genuine hardship. The High Court quashed the impugned order, directing the respondent to condone the delay in filing Form 10B to enable the petitioner to obtain exemption u/s 11.
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