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...
ITAT held that Section 56(2)(x) cannot be applied retrospectively to a property transfer concluded by agreement in 2010; the tribunal accepted uncontested facts that substantial payments and possession occurred after the 2010 agreement and that subsequent registration in 2018 did not convert the pre-existing transaction into one chargeable under that provision. CIT(A)'s technical dismissal on advance-tax and belated return grounds did not address the substantive legal point. Applying the principle that a provision does not apply to agreements concluded prior to its enactment, the addition under Section 56(2)(x) was deleted and the appeal allowed for AY 2018-19.
ITAT held that Section 56(2)(x) cannot be applied retrospectively to a property transfer concluded by agreement in 2010; the tribunal accepted uncontested facts that substantial payments and possession occurred after the 2010 agreement and that subsequent registration in 2018 did not convert the pre-existing transaction into one chargeable under that provision. CIT(A)'s technical dismissal on advance-tax and belated return grounds did not address the substantive legal point. Applying the principle that a provision does not apply to agreements concluded prior to its enactment, the addition under Section 56(2)(x) was deleted and the appeal allowed for AY 2018-19.
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TaxTMI 
TaxTMI 
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