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...
ITAT set aside CIT(A)'s orders concerning taxation of rental income earned by an AOP under s.167B. While co-ownership agreement specified determinate shares, verification of individual members' tax rates was deemed necessary. The Tribunal held that if any AOP member is taxable at rates higher than MMR, entire AOP income must be taxed at MMR per s.167B. Matter remanded to AO for verification of co-owners' applicable tax rates from individual returns. If no member exceeds MMR threshold, income to be taxed at normal slab rates under s.167B(2). Conversely, if any member's rate exceeds MMR, AOP's entire income shall be taxed at MMR. Appeals allowed for statistical purposes.
ITAT set aside CIT(A)'s orders concerning taxation of rental income earned by an AOP under s.167B. While co-ownership agreement specified determinate shares, verification of individual members' tax rates was deemed necessary. The Tribunal held that if any AOP member is taxable at rates higher than MMR, entire AOP income must be taxed at MMR per s.167B. Matter remanded to AO for verification of co-owners' applicable tax rates from individual returns. If no member exceeds MMR threshold, income to be taxed at normal slab rates under s.167B(2). Conversely, if any member's rate exceeds MMR, AOP's entire income shall be taxed at MMR. Appeals allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
