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...
The High Court addressed two issues: disallowance of deduction u/s 10B and non-compliance with Section 153C procedure. Regarding Section 10B, the Court upheld the Tribunal's decision based on its previous judgment in Tata Elxsi Ltd. As for Section 153C, the Court reiterated that when search material is relied upon, the Assessing Officer must follow the procedure u/ss 153A, 153B, and 153C, and cannot continue with regular assessment. The Court relied on its decision in Dinakar Suvarna and ruled in favor of the assessee on both issues.
The High Court addressed two issues: disallowance of deduction u/s 10B and non-compliance with Section 153C procedure. Regarding Section 10B, the Court upheld the Tribunal's decision based on its previous judgment in Tata Elxsi Ltd. As for Section 153C, the Court reiterated that when search material is relied upon, the Assessing Officer must follow the procedure u/ss 153A, 153B, and 153C, and cannot continue with regular assessment. The Court relied on its decision in Dinakar Suvarna and ruled in favor of the assessee on both issues.
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TaxTMI 
TaxTMI 
of 4918 
