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...
HC determined that interest received for delayed compensation in compulsory land acquisition qualifies as part of the principal compensation amount. The interest shall be classified as "Capital Gains" under the I.T. Act and eligible for exemption under Section 10(37) if the acquired land is agricultural. The court held that such interest payments are not standalone interest as defined under Section 2(28A), and Section 56 provisions will not automatically apply. The determination depends on the specific factual context of each case. Ultimately, the decision was rendered in favor of the assessee, establishing that statutory interest in property acquisition scenarios should be treated as an integral component of the compensation itself.
HC determined that interest received for delayed compensation in compulsory land acquisition qualifies as part of the principal compensation amount. The interest shall be classified as "Capital Gains" under the I.T. Act and eligible for exemption under Section 10(37) if the acquired land is agricultural. The court held that such interest payments are not standalone interest as defined under Section 2(28A), and Section 56 provisions will not automatically apply. The determination depends on the specific factual context of each case. Ultimately, the decision was rendered in favor of the assessee, establishing that statutory interest in property acquisition scenarios should be treated as an integral component of the compensation itself.
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