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...
The HC dismissed a petition challenging denial of exemption under section 10(23C)(vi) of the Income Tax Act. The petitioner-trust argued that income received solely for educational purposes should be exempt. However, the Court upheld the Chief Commissioner of Income Tax's determination, noting that the exemption was claimed by the trust itself rather than by the specific educational institution (GHG Academy) it operated. Since it could not be conclusively established that the trust existed solely for educational purposes and not for profit, the Court found that exemption was correctly denied under the statutory requirements.
The HC dismissed a petition challenging denial of exemption under section 10(23C)(vi) of the Income Tax Act. The petitioner-trust argued that income received solely for educational purposes should be exempt. However, the Court upheld the Chief Commissioner of Income Tax's determination, noting that the exemption was claimed by the trust itself rather than by the specific educational institution (GHG Academy) it operated. Since it could not be conclusively established that the trust existed solely for educational purposes and not for profit, the Court found that exemption was correctly denied under the statutory requirements.
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