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...
ITAT held that a one-time life-membership fee received by the assessee-trust is a capital receipt apportioned over 40 years under a long-standing accounting practice accepted by revenue; thus the fee constitutes a timing difference rather than current revenue. Relying on the principle that where tax rates across years remain constant no addition is warranted, ITAT rejected revenue's attempt to treat the entire fee as taxable in the year of receipt. The Assessing Officer is directed to exclude the apportioned corpus sum from computation of application of income for charitable purposes and to ignore the said amount when determining exemption under section 11.
ITAT held that a one-time life-membership fee received by the assessee-trust is a capital receipt apportioned over 40 years under a long-standing accounting practice accepted by revenue; thus the fee constitutes a timing difference rather than current revenue. Relying on the principle that where tax rates across years remain constant no addition is warranted, ITAT rejected revenue's attempt to treat the entire fee as taxable in the year of receipt. The Assessing Officer is directed to exclude the apportioned corpus sum from computation of application of income for charitable purposes and to ignore the said amount when determining exemption under section 11.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
