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...
The ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
The ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
