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...
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
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TaxTMI 
TaxTMI 
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