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 ITAT upheld that the exemption under Section 10(10D) does not apply where a life insurance policy is surrendered and the single premium paid exceeds 20% of the capital sum assured, thereby disallowing the exemption on maturity proceeds received upon surrender. However, the Tribunal found that the Assessing Officer's addition was based on an incorrect charging section and erroneous appreciation of facts. Following precedent, the ITAT held that additions made without proper legal basis are unsustainable and invalid. Consequently, the impugned additions were deemed arbitrary and perverse, leading to their deletion. The appellant's appeal was allowed in full.
The ITAT upheld that the exemption under Section 10(10D) does not apply where a life insurance policy is surrendered and the single premium paid exceeds 20% of the capital sum assured, thereby disallowing the exemption on maturity proceeds received upon surrender. However, the Tribunal found that the Assessing Officer's addition was based on an incorrect charging section and erroneous appreciation of facts. Following precedent, the ITAT held that additions made without proper legal basis are unsustainable and invalid. Consequently, the impugned additions were deemed arbitrary and perverse, leading to their deletion. The appellant's appeal was allowed in full.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
