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 allowed the appeal of the assessee, holding that denial of exemption u/s 11 on account of delayed filing or non-simultaneous uploading of the audit report in Form No.10B is impermissible where substantive statutory conditions for exemption are satisfied. The Tribunal determined the requirement to file Form No.10B with the return is procedural/directory, not mandatory, and technical discrepancies (including an incorrect entry of section 10(23C)(iv) instead of section 11) cannot defeat the assessee's substantive right to exemption. Consequently, the CPC and JCIT(A)'s actions assessing gross receipts as taxable income were set aside and the exemption u/s 11 was restored.
ITAT allowed the appeal of the assessee, holding that denial of exemption u/s 11 on account of delayed filing or non-simultaneous uploading of the audit report in Form No.10B is impermissible where substantive statutory conditions for exemption are satisfied. The Tribunal determined the requirement to file Form No.10B with the return is procedural/directory, not mandatory, and technical discrepancies (including an incorrect entry of section 10(23C)(iv) instead of section 11) cannot defeat the assessee's substantive right to exemption. Consequently, the CPC and JCIT(A)'s actions assessing gross receipts as taxable income were set aside and the exemption u/s 11 was restored.
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