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...
Transfer pricing adjustment for intra-group steam transfers was deleted after the appellate tribunal found the TPO/AO disregarded binding DRP directions and precedent; arm's length re determination was not sustained. The claim for enhanced deduction on steam transferred from an eligible captive unit to non eligible units was remitted to the Assessing Officer for verification and decision with an opportunity to be heard. Receipts from Renewable Energy Certificates were held to be capital receipts and excluded from book profits for MAT purposes. A suo motu disallowance under the rule for exempt income was deleted where no exempt income was earned.
Transfer pricing adjustment for intra-group steam transfers was deleted after the appellate tribunal found the TPO/AO disregarded binding DRP directions and precedent; arm's length re determination was not sustained. The claim for enhanced deduction on steam transferred from an eligible captive unit to non eligible units was remitted to the Assessing Officer for verification and decision with an opportunity to be heard. Receipts from Renewable Energy Certificates were held to be capital receipts and excluded from book profits for MAT purposes. A suo motu disallowance under the rule for exempt income was deleted where no exempt income was earned.
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