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 regarding utilization of accumulated charitable funds under Section 11(3). The assessee accumulated funds in FY 2016-17 and utilized Rs. 2,32,073 during the additional one-year period in FY 2022-23, claiming deduction for AY 2023-24. CPC disallowed the claim citing Finance Act 2022 amendment removing the additional year provision effective 01.04.2023. ITAT held that applying the amendment retrospectively would create an impossible situation under the doctrine of impossibility (lex non cogit ad inpossibilia), as the assessee would be left with no time to utilize accumulated funds. The amendment cannot be interpreted to make fund utilization impossible within the originally provided timeframe. Legal obligations must be interpreted with practicality and reasonableness considering specific circumstances. The adjustment made during return processing was deleted.
ITAT allowed the appeal regarding utilization of accumulated charitable funds under Section 11(3). The assessee accumulated funds in FY 2016-17 and utilized Rs. 2,32,073 during the additional one-year period in FY 2022-23, claiming deduction for AY 2023-24. CPC disallowed the claim citing Finance Act 2022 amendment removing the additional year provision effective 01.04.2023. ITAT held that applying the amendment retrospectively would create an impossible situation under the doctrine of impossibility (lex non cogit ad inpossibilia), as the assessee would be left with no time to utilize accumulated funds. The amendment cannot be interpreted to make fund utilization impossible within the originally provided timeframe. Legal obligations must be interpreted with practicality and reasonableness considering specific circumstances. The adjustment made during return processing was deleted.
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