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...
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An agreement must be read as a whole; on that basis the authorities correctly found that the JDA constituted a transfer of land chargeable in AY 2005 06, but the court directed that capital gains should not be taxed again in AY 2005 06 where the same sale consideration has already been subjected to tax in AYs 2007 08 and 2008 09. The principle that income is taxable in the relevant assessment year and in the hands of the correct assessee was applied, and the capital gains addition for AY 2005 06 was set aside subject to verification by the Assessing Officer that the consideration was already taxed later.
An agreement must be read as a whole; on that basis the authorities correctly found that the JDA constituted a transfer of land chargeable in AY 2005 06, but the court directed that capital gains should not be taxed again in AY 2005 06 where the same sale consideration has already been subjected to tax in AYs 2007 08 and 2008 09. The principle that income is taxable in the relevant assessment year and in the hands of the correct assessee was applied, and the capital gains addition for AY 2005 06 was set aside subject to verification by the Assessing Officer that the consideration was already taxed later.
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