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...
ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority's order and directed deletion of the adjustment, allowing the assessee's grounds.
ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority's order and directed deletion of the adjustment, allowing the assessee's grounds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
