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...
Issue concerned eligibility for deduction under Section 80-IC where assessee manufactured some items listed in the Fourteenth Schedule but not those in the Thirteenth Schedule. Tribunal rejected the Revenue's contention that manufacture of Fourteenth Schedule items alone invoked Section 80-IC(2)(b); instead eligibility was determined by location in a notified eligible area and commencement of production within the specified period. Result: assessee entitled to benefit under Section 80-IC(2)(a)(ii) on satisfying location and commencement criteria, not merely by producing certain Fourteenth Schedule goods.
Issue concerned eligibility for deduction under Section 80-IC where assessee manufactured some items listed in the Fourteenth Schedule but not those in the Thirteenth Schedule. Tribunal rejected the Revenue's contention that manufacture of Fourteenth Schedule items alone invoked Section 80-IC(2)(b); instead eligibility was determined by location in a notified eligible area and commencement of production within the specified period. Result: assessee entitled to benefit under Section 80-IC(2)(a)(ii) on satisfying location and commencement criteria, not merely by producing certain Fourteenth Schedule goods.
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