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...
This case deals with the deduction u/s 80DD of the Income Tax Act for maintaining and providing medical treatment to a dependent person with disability. The key points are: The petitioner sought retrospective application of an amendment to Section 80DD, allowing deduction for payment of annuity or lump sum for the benefit of a disabled dependent after the subscriber's death. The court rejected the plea for retrospective application, as it would go against the object of the insurance policy taken for the disabled person's benefit after the subscriber's demise. Giving retrospective effect would remove the substratum of the insurance contract, a commercial agreement with specific terms and conditions. The court considered various laws and conventions related to the rights and welfare of persons with disabilities. The grievance of the petitioner was addressed prospectively through the amendment to Section 80DD, as per the court's earlier order.
This case deals with the deduction u/s 80DD of the Income Tax Act for maintaining and providing medical treatment to a dependent person with disability. The key points are: The petitioner sought retrospective application of an amendment to Section 80DD, allowing deduction for payment of annuity or lump sum for the benefit of a disabled dependent after the subscriber's death. The court rejected the plea for retrospective application, as it would go against the object of the insurance policy taken for the disabled person's benefit after the subscriber's demise. Giving retrospective effect would remove the substratum of the insurance contract, a commercial agreement with specific terms and conditions. The court considered various laws and conventions related to the rights and welfare of persons with disabilities. The grievance of the petitioner was addressed prospectively through the amendment to Section 80DD, as per the court's earlier order.
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