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...
Leased premises used as a hotel, though containing a restaurant, banquet and conference halls, bar and health club, qualify as a building used for accommodation and thus fall within the renting of immovable property exclusion; the Tribunal found those facilities to be integral or incidental to hotel activity rather than separate commercial deployments and held that Explanation 2 deeming partial business use is not attracted. Applying the plain-text exclusion and following prior coordinate-bench reasoning affirmed by higher authority, the impugned demand and orders were set aside with consequential relief.
Leased premises used as a hotel, though containing a restaurant, banquet and conference halls, bar and health club, qualify as a building used for accommodation and thus fall within the renting of immovable property exclusion; the Tribunal found those facilities to be integral or incidental to hotel activity rather than separate commercial deployments and held that Explanation 2 deeming partial business use is not attracted. Applying the plain-text exclusion and following prior coordinate-bench reasoning affirmed by higher authority, the impugned demand and orders were set aside with consequential relief.
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