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 appeal regarding surcharge computation on private discretionary trust income. The tribunal held that CIT(A) erroneously determined the entire trust income should attract Maximum Marginal Rate with 37% surcharge under section 167B read with section 2(29C). Following precedent in Araadhya Jain Trust, ITAT ruled the assessee correctly claimed 15% surcharge rate in its return. The Assessing Officer appropriately allowed this claim through rectification order. The appellate authority's decision to impose 37% surcharge on trust income was overturned, with ITAT confirming the lower 15% surcharge rate applies to the trust's taxable income assessment.
ITAT allowed the appeal regarding surcharge computation on private discretionary trust income. The tribunal held that CIT(A) erroneously determined the entire trust income should attract Maximum Marginal Rate with 37% surcharge under section 167B read with section 2(29C). Following precedent in Araadhya Jain Trust, ITAT ruled the assessee correctly claimed 15% surcharge rate in its return. The Assessing Officer appropriately allowed this claim through rectification order. The appellate authority's decision to impose 37% surcharge on trust income was overturned, with ITAT confirming the lower 15% surcharge rate applies to the trust's taxable income assessment.
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