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 ITAT dismissed the assessee's appeal regarding donations made to an unregistered trust under section 12A, affirming that exemption under section 11(1)(a) requires the recipient entity to be registered. The assessee failed to provide evidence that expenditures were for charitable purposes. However, the Tribunal allowed various expenses as valid application of income, including interest on TDS, statutory penalties, gifts, cultural expenditures, and ITC write-offs, considering them incidental to charitable activities based on precedents including CIT v. Trustee of H.E.H. the Nizam's Supplemental Religious Endowment Trust and CIT v. Surat Art Silk Cloth Manufacturers Association. The ITAT also permitted accumulation of income under section 11(2), ruling that bank deposits and lien-free FDRs qualify as investments under section 11(5).
The ITAT dismissed the assessee's appeal regarding donations made to an unregistered trust under section 12A, affirming that exemption under section 11(1)(a) requires the recipient entity to be registered. The assessee failed to provide evidence that expenditures were for charitable purposes. However, the Tribunal allowed various expenses as valid application of income, including interest on TDS, statutory penalties, gifts, cultural expenditures, and ITC write-offs, considering them incidental to charitable activities based on precedents including CIT v. Trustee of H.E.H. the Nizam's Supplemental Religious Endowment Trust and CIT v. Surat Art Silk Cloth Manufacturers Association. The ITAT also permitted accumulation of income under section 11(2), ruling that bank deposits and lien-free FDRs qualify as investments under section 11(5).
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