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 HC quashed the denial of benefits under Section 115BAB, ruling that filing Form 10-ID after the due date was a procedural lapse that should not invalidate the substantive benefit already claimed in the tax return. The court held that once a benefit is claimed in the income tax return, filing a separate form is merely procedural and should not be denied if sufficient cause for delay exists. The issuance of multiple CBDT Circulars (6/2022, 19/2023, and 17/2024) demonstrated widespread difficulties with timely filing of Forms 10-IC and 10-ID. The court directed authorities to accept the petitioner's Form 10-ID filed on 12.09.2022 as legal and valid despite the delay.
The HC quashed the denial of benefits under Section 115BAB, ruling that filing Form 10-ID after the due date was a procedural lapse that should not invalidate the substantive benefit already claimed in the tax return. The court held that once a benefit is claimed in the income tax return, filing a separate form is merely procedural and should not be denied if sufficient cause for delay exists. The issuance of multiple CBDT Circulars (6/2022, 19/2023, and 17/2024) demonstrated widespread difficulties with timely filing of Forms 10-IC and 10-ID. The court directed authorities to accept the petitioner's Form 10-ID filed on 12.09.2022 as legal and valid despite the delay.
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TaxTMI 
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