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 findings of the NFAC and ITAT, affirming that the assessee lawfully accumulated less than 15% of its total receipts under section 11(1)(a) for specific purposes. The capital expenditure, including Rs. 3.14 crores accumulated previously and Rs. 2.89 crores utilized in the current year, was correctly treated as part of charitable activities. The outlay of Rs. 8.4 crores on the RO water treatment plant and Rs. 30 lakhs on solar lantern distribution were also held to be in furtherance of charitable purposes. The Revenue failed to demonstrate any error of law or perversity in the factual findings by NFAC and ITAT. Consequently, no substantial question of law arose, resulting in dismissal of the Revenue's appeal. The exemption under section 11 was thus confirmed.
The HC upheld the findings of the NFAC and ITAT, affirming that the assessee lawfully accumulated less than 15% of its total receipts under section 11(1)(a) for specific purposes. The capital expenditure, including Rs. 3.14 crores accumulated previously and Rs. 2.89 crores utilized in the current year, was correctly treated as part of charitable activities. The outlay of Rs. 8.4 crores on the RO water treatment plant and Rs. 30 lakhs on solar lantern distribution were also held to be in furtherance of charitable purposes. The Revenue failed to demonstrate any error of law or perversity in the factual findings by NFAC and ITAT. Consequently, no substantial question of law arose, resulting in dismissal of the Revenue's appeal. The exemption under section 11 was thus confirmed.
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TaxTMI 
TaxTMI 
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