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 partially allowed the appeal, ruling on two key issues. First, it confirmed that lands in Egathur and Navalur Villages qualified as agricultural lands under s.2(14) of the Act, being situated beyond 8km from municipal limits, thus exempt from being considered capital assets. The HC held that "Municipality" encompasses all local bodies regardless of specific nomenclature. Second, regarding NABARD bonds investment for s.54EC deduction, the HC reversed the Tribunal's finding, determining that the assessee could claim exemption only to the extent of Rs. 8,55,54,167/- out of Rs. 10 Crores, as funds from a property sold on 13.02.2006 were not available for investment made on 26.11.2005.
The HC partially allowed the appeal, ruling on two key issues. First, it confirmed that lands in Egathur and Navalur Villages qualified as agricultural lands under s.2(14) of the Act, being situated beyond 8km from municipal limits, thus exempt from being considered capital assets. The HC held that "Municipality" encompasses all local bodies regardless of specific nomenclature. Second, regarding NABARD bonds investment for s.54EC deduction, the HC reversed the Tribunal's finding, determining that the assessee could claim exemption only to the extent of Rs. 8,55,54,167/- out of Rs. 10 Crores, as funds from a property sold on 13.02.2006 were not available for investment made on 26.11.2005.
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