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 set aside the impugned appellate order and remanded the matter to the AO for fresh quantification of the addition, directing recomputation in accordance with law after affording the assessee a reasonable opportunity to be heard. Tribunal held that, although approval under s.10(23C) existed, the assessee consciously elected to claim exemption under s.11 read with s.12A in the assessment proceedings and therefore CIT(A) erred in granting benefit under s.10(23C) which was not pleaded before the AO. The question of quantum of addition (previously disputed between specified amounts) is restored to the file of the AO for verification and determination consistent with this decision.
ITAT set aside the impugned appellate order and remanded the matter to the AO for fresh quantification of the addition, directing recomputation in accordance with law after affording the assessee a reasonable opportunity to be heard. Tribunal held that, although approval under s.10(23C) existed, the assessee consciously elected to claim exemption under s.11 read with s.12A in the assessment proceedings and therefore CIT(A) erred in granting benefit under s.10(23C) which was not pleaded before the AO. The question of quantum of addition (previously disputed between specified amounts) is restored to the file of the AO for verification and determination consistent with this decision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
