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...
Eligibility for rebate under section 87A was contested for tax components including shortterm capital gains taxed at special rates, longterm capital gains, and tax on transfer of virtual digital assets. The tribunal found that the statutory language and existing precedents permit rebate against tax on shortterm capital gains taxed under the special rate provision, and directed allowance of the rebate (Rs. 13,320) with recomputation of tax. The tribunal rejected the claim for rebate against tax on income from transfer of virtual digital assets, leaving that element unaffected. The assessee had opted for the new tax regime; a prospective legislative amendment clarified intent but did not alter the outcome for the year in question.
Eligibility for rebate under section 87A was contested for tax components including shortterm capital gains taxed at special rates, longterm capital gains, and tax on transfer of virtual digital assets. The tribunal found that the statutory language and existing precedents permit rebate against tax on shortterm capital gains taxed under the special rate provision, and directed allowance of the rebate (Rs. 13,320) with recomputation of tax. The tribunal rejected the claim for rebate against tax on income from transfer of virtual digital assets, leaving that element unaffected. The assessee had opted for the new tax regime; a prospective legislative amendment clarified intent but did not alter the outcome for the year in question.
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