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 held that the assessee, being a domestic company which elected taxation under section 115BAA by filing Form 10IC for FY 2019-20 and subsequent years, is taxable at the prescribed flat rate of 22% on its total income, including long-term capital gains. The Tribunal found no merit in applying the concessional 20% rate under section 112 and upheld the order of the CIT(A). Consequentially, the appeal is dismissed and the assessment stands confirmed at the 22% rate pursuant to the assessee's valid exercise of the 115BAA option.
ITAT held that the assessee, being a domestic company which elected taxation under section 115BAA by filing Form 10IC for FY 2019-20 and subsequent years, is taxable at the prescribed flat rate of 22% on its total income, including long-term capital gains. The Tribunal found no merit in applying the concessional 20% rate under section 112 and upheld the order of the CIT(A). Consequentially, the appeal is dismissed and the assessment stands confirmed at the 22% rate pursuant to the assessee's valid exercise of the 115BAA option.
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