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 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
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