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...
Section 80CCC(2) applies only when the assessee has claimed and been allowed a deduction u/s 80CCC(1). Since the assessee did not claim deduction u/s 80CCC(1), Section 80CCC(2) is inapplicable. The accretion of Rs. 16,39,726 from premature surrender of pension policies requires examination u/s 10(10D) to determine eligibility for exemption. The matter is restored to the Assessing Officer to examine the exemption eligibility u/s 10(10D). The assessee's appeal is partly allowed.
Section 80CCC(2) applies only when the assessee has claimed and been allowed a deduction u/s 80CCC(1). Since the assessee did not claim deduction u/s 80CCC(1), Section 80CCC(2) is inapplicable. The accretion of Rs. 16,39,726 from premature surrender of pension policies requires examination u/s 10(10D) to determine eligibility for exemption. The matter is restored to the Assessing Officer to examine the exemption eligibility u/s 10(10D). The assessee's appeal is partly allowed.
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TaxTMI 
TaxTMI 
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