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...
Validity of revision under assessment revision power was contested where AO allowed exemption for investment in venture capital undertakings; HC/ITAT found AO had applied mind after detailed enquiry, making PCITs substitution of opinion impermissible, and restored the assessment. Tribunal noted investments taxed in unit holders hands so revenue suffered no prejudice, SEBI VCF Regulations permit temporary mutual fund investments, and the VCF Regulations (post amendment) no longer exclude real estate, so investments in real estate VCUs did not breach regulatory eligibility for the exemption.
Validity of revision under assessment revision power was contested where AO allowed exemption for investment in venture capital undertakings; HC/ITAT found AO had applied mind after detailed enquiry, making PCITs substitution of opinion impermissible, and restored the assessment. Tribunal noted investments taxed in unit holders hands so revenue suffered no prejudice, SEBI VCF Regulations permit temporary mutual fund investments, and the VCF Regulations (post amendment) no longer exclude real estate, so investments in real estate VCUs did not breach regulatory eligibility for the exemption.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
