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...
HC allowed the Appellant's claim for deduction under section 80IA of the IT Act, holding that interest earned on fixed deposits and on TDS refunds was deductible as income "derived from" the eligible business. The court found the deposits were placed for business purposes (equipment replacement and crane acquisition) and not merely to park surplus funds, establishing a direct nexus between the interest and the eligible container-terminal operations. The HC reversed the assessing officer's treatment of such interest as "income from other sources," concluding the interest was incidental to and integrally connected with the eligible business and therefore eligible for s.80IA relief.
HC allowed the Appellant's claim for deduction under section 80IA of the IT Act, holding that interest earned on fixed deposits and on TDS refunds was deductible as income "derived from" the eligible business. The court found the deposits were placed for business purposes (equipment replacement and crane acquisition) and not merely to park surplus funds, establishing a direct nexus between the interest and the eligible container-terminal operations. The HC reversed the assessing officer's treatment of such interest as "income from other sources," concluding the interest was incidental to and integrally connected with the eligible business and therefore eligible for s.80IA relief.
Note: It is a system-generated summary and is for quick reference only.
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