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...
Registration under s.12AA was denied because the applicant's stated objects and actual activities were predominantly software development and start-up consultancy, which did not fall within any limb of "charitable purpose" under s.2(15). The authority further held that the applicant's dominant financing from a commercial entity, linked to strategic advisory arrangements, did not constitute income eligible for exemption under ss.11-12, as the receipts were in substance consideration for commercial services. In the absence of any material rebutting these findings, the denial of registration was upheld and the appeal was dismissed - ITAT
Registration under s.12AA was denied because the applicant's stated objects and actual activities were predominantly software development and start-up consultancy, which did not fall within any limb of "charitable purpose" under s.2(15). The authority further held that the applicant's dominant financing from a commercial entity, linked to strategic advisory arrangements, did not constitute income eligible for exemption under ss.11-12, as the receipts were in substance consideration for commercial services. In the absence of any material rebutting these findings, the denial of registration was upheld and the appeal was dismissed - ITAT
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TaxTMI 
TaxTMI 
of 4918 
