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...
ITAT partially allowed the assessee's appeal regarding deduction u/s 80JJA and expenses allocation u/s 14A. The Tribunal directed the AO to re-examine the five-year deduction period for bio-fertilizer business and verify asset and expense allocations between agricultural and non-agricultural activities. Specifically, the Tribunal upheld proportionate allocation of employee benefit expenses, deleted finance cost allocation, and directed detailed verification of depreciation and other expenses related to agricultural operations. The appeal was allowed for statistical purposes with specific directions to the Assessing Officer for further examination and re-assessment.
ITAT partially allowed the assessee's appeal regarding deduction u/s 80JJA and expenses allocation u/s 14A. The Tribunal directed the AO to re-examine the five-year deduction period for bio-fertilizer business and verify asset and expense allocations between agricultural and non-agricultural activities. Specifically, the Tribunal upheld proportionate allocation of employee benefit expenses, deleted finance cost allocation, and directed detailed verification of depreciation and other expenses related to agricultural operations. The appeal was allowed for statistical purposes with specific directions to the Assessing Officer for further examination and re-assessment.
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