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...
The HC upheld the factual findings of the ITAT and CIT(A) that construction commenced after 1st October 1998, entitling the assessee to claim deduction under section 80IB(10), subject to other conditions. Regarding disallowance under section 14A read with Rule 8D, the HC concurred with the ITAT that Rule 8D applies prospectively from AY 2008-09 onwards. Consequently, the CIT(A)'s restriction of disallowance to 10% of exempt income was upheld as valid. The Court found no substantial question of law warranting interference, affirming the lower authorities' decisions on both issues.
The HC upheld the factual findings of the ITAT and CIT(A) that construction commenced after 1st October 1998, entitling the assessee to claim deduction under section 80IB(10), subject to other conditions. Regarding disallowance under section 14A read with Rule 8D, the HC concurred with the ITAT that Rule 8D applies prospectively from AY 2008-09 onwards. Consequently, the CIT(A)'s restriction of disallowance to 10% of exempt income was upheld as valid. The Court found no substantial question of law warranting interference, affirming the lower authorities' decisions on both issues.
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