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...
ITAT holds that condonation of delay u/s 119(2)(b) validates the assessee's option under s.115BAA, rendering the sole dispute concerning denial of the concessional 22% rate moot. The Tribunal sets aside the order of the CIT(A) and restores the matter to the file of the AO with directions that the AO: (i) take cognizance of the condonation order dated 11.09.2025 passed by the PCIT u/s 119(2)(b); (ii) verify electronic filing of Form No.10-IC and recompute tax liability at 22% u/s 115BAA; and (iii) afford the assessee an opportunity of being heard before giving effect to these directions. The assessee's appeal is allowed for statistical purposes.
ITAT holds that condonation of delay u/s 119(2)(b) validates the assessee's option under s.115BAA, rendering the sole dispute concerning denial of the concessional 22% rate moot. The Tribunal sets aside the order of the CIT(A) and restores the matter to the file of the AO with directions that the AO: (i) take cognizance of the condonation order dated 11.09.2025 passed by the PCIT u/s 119(2)(b); (ii) verify electronic filing of Form No.10-IC and recompute tax liability at 22% u/s 115BAA; and (iii) afford the assessee an opportunity of being heard before giving effect to these directions. The assessee's appeal is allowed for statistical purposes.
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