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...
An estate is assessable under section 168 on income accruing from a deceased person's assets after death, and TDS credit on dividend income belongs to the estate only if the income relates wholly to the post-death period. The ITAT found the legal position undisputed but the record insufficient to decide the relevant period, so the Assessing Officer was directed to verify that fact and grant TDS credit accordingly if the income was post-death. It also held that the Addl./Joint CIT(A) had no power to remand the matter to the Assessing Officer under section 251 in the circumstances, and disapproved that course.
An estate is assessable under section 168 on income accruing from a deceased person's assets after death, and TDS credit on dividend income belongs to the estate only if the income relates wholly to the post-death period. The ITAT found the legal position undisputed but the record insufficient to decide the relevant period, so the Assessing Officer was directed to verify that fact and grant TDS credit accordingly if the income was post-death. It also held that the Addl./Joint CIT(A) had no power to remand the matter to the Assessing Officer under section 251 in the circumstances, and disapproved that course.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
