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 upholds CIT(A)'s factual finding that the assessee's current-year loss of Rs.2.38 crore constituted unabsorbed depreciation, not business loss, and therefore is eligible for carry-forward after set-off against income from house property, capital gains and other sources. The Departmental Representative conceded the factual finding; Revenue's ground challenging that finding was held to be without merit. ITAT further held that, under s.32(2) read with s.80, the assessee need not specifically claim unabsorbed depreciation in a return filed under s.139(1) to carry it forward, and consequently the appeal by Revenue fails and the assessees' entitlement to carry-forward unabsorbed depreciation is affirmed.
ITAT upholds CIT(A)'s factual finding that the assessee's current-year loss of Rs.2.38 crore constituted unabsorbed depreciation, not business loss, and therefore is eligible for carry-forward after set-off against income from house property, capital gains and other sources. The Departmental Representative conceded the factual finding; Revenue's ground challenging that finding was held to be without merit. ITAT further held that, under s.32(2) read with s.80, the assessee need not specifically claim unabsorbed depreciation in a return filed under s.139(1) to carry it forward, and consequently the appeal by Revenue fails and the assessees' entitlement to carry-forward unabsorbed depreciation is affirmed.
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