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...
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The HC upheld the Tribunal's remand to the AO for fresh adjudication on the assessee's entitlement to deductions under s.80JJA for AYs 2007-08 and 2008-09, finding no infirmity warranting rectification of the Tribunal's order and affirming the Tribunal's power under s.254 to remit for reconsideration; the Court noted that the claim under s.80JJA could not be arbitrarily disallowed where it had been allowed in earlier years on identical facts. Separately, the HC found the addition u/s 68 unsustainable on the record, observed that bank payments and confirmations substantiated the sundry creditors, and remitted the matter to the AO for de novo assessment.
The HC upheld the Tribunal's remand to the AO for fresh adjudication on the assessee's entitlement to deductions under s.80JJA for AYs 2007-08 and 2008-09, finding no infirmity warranting rectification of the Tribunal's order and affirming the Tribunal's power under s.254 to remit for reconsideration; the Court noted that the claim under s.80JJA could not be arbitrarily disallowed where it had been allowed in earlier years on identical facts. Separately, the HC found the addition u/s 68 unsustainable on the record, observed that bank payments and confirmations substantiated the sundry creditors, and remitted the matter to the AO for de novo assessment.
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