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 assessee was a member of syndicates (association of persons or body of individuals) and had received share of profits from them. The tax authorities sought to tax the assessee's share of profits from the syndicates in the assessee's hands, but the ITAT deleted the addition. The High Court upheld the ITAT's decision, holding that when an assessee is a member of an AOP/BOI and the income earned from such AOP/BOI has been offered to tax, then the share received by the assessee from such AOP/BOI after payment of due taxes cannot be taxed again in the assessee's hands, as per Section 86(a) proviso read with Section 67A. The court agreed with the ITAT that the income was rightly assessed in the hands of the syndicates, and a direct assessment of the same income in the assessee's hands was not justified. The court found no substantial question of law arising from the ITAT's order.
The assessee was a member of syndicates (association of persons or body of individuals) and had received share of profits from them. The tax authorities sought to tax the assessee's share of profits from the syndicates in the assessee's hands, but the ITAT deleted the addition. The High Court upheld the ITAT's decision, holding that when an assessee is a member of an AOP/BOI and the income earned from such AOP/BOI has been offered to tax, then the share received by the assessee from such AOP/BOI after payment of due taxes cannot be taxed again in the assessee's hands, as per Section 86(a) proviso read with Section 67A. The court agreed with the ITAT that the income was rightly assessed in the hands of the syndicates, and a direct assessment of the same income in the assessee's hands was not justified. The court found no substantial question of law arising from the ITAT's order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
