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...
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ITAT allowed the assessee's appeal, holding that license fees from commercial spaces in mall/warehouse should be assessed under house property income, consistent with previous years' treatment. The tribunal directed the Assessing Officer to assess income under house property and delete the addition to total income. Additionally, the ITAT found the section 143(2) notice invalid due to non-compliance with CBDT instructions, rendering the entire assessment proceeding void. The decision upheld the principle of maintaining consistent income classification across assessment years and emphasized procedural compliance in tax proceedings.
ITAT allowed the assessee's appeal, holding that license fees from commercial spaces in mall/warehouse should be assessed under house property income, consistent with previous years' treatment. The tribunal directed the Assessing Officer to assess income under house property and delete the addition to total income. Additionally, the ITAT found the section 143(2) notice invalid due to non-compliance with CBDT instructions, rendering the entire assessment proceeding void. The decision upheld the principle of maintaining consistent income classification across assessment years and emphasized procedural compliance in tax proceedings.
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