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...
The ITAT allowed the appeal, holding that the assessee remains entitled to the deduction under section 80IC where the claim was made in the original return of income filed under section 139(1) and persisted in the revised return under section 139(5). The Tribunal held that the statutory requirement to claim the deduction pertains to submission in the return as governed by section 80AC and that revision under section 139(5) does not by itself bar the claim. Further, delay in submission of the statutory audit report (Form 10CCB) was held to be directory rather than mandatory if the audit report is furnished prior to completion of assessment. Grounds raised by the assessee were allowed.
The ITAT allowed the appeal, holding that the assessee remains entitled to the deduction under section 80IC where the claim was made in the original return of income filed under section 139(1) and persisted in the revised return under section 139(5). The Tribunal held that the statutory requirement to claim the deduction pertains to submission in the return as governed by section 80AC and that revision under section 139(5) does not by itself bar the claim. Further, delay in submission of the statutory audit report (Form 10CCB) was held to be directory rather than mandatory if the audit report is furnished prior to completion of assessment. Grounds raised by the assessee were allowed.
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