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 ruled that Section 80IB(10) deduction remains available for AY 2006-2007, with Section 80AC restriction not retroactively applicable. The benefit can be claimed for AY 2007-2008 onwards, subject to potential legal challenge in separate proceedings. The substantial questions of law were partly answered against the assessee for AY 2007-2008 to 2011-2012, while AY 2006-2007 was decided in the assessee's favor, consistent with precedential judicial interpretations regarding tax deduction provisions.
HC ruled that Section 80IB(10) deduction remains available for AY 2006-2007, with Section 80AC restriction not retroactively applicable. The benefit can be claimed for AY 2007-2008 onwards, subject to potential legal challenge in separate proceedings. The substantial questions of law were partly answered against the assessee for AY 2007-2008 to 2011-2012, while AY 2006-2007 was decided in the assessee's favor, consistent with precedential judicial interpretations regarding tax deduction provisions.
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