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...
For private discretionary trusts whose income is chargeable at the maximum marginal rate, surcharge on income tax is to be computed by reference to the slab rates prescribed in the Finance Act for the relevant year. Applying the Special Bench ruling in Aradhya Jain Trust, the ITAT held that the assessee correctly claimed surcharge at 15% and that the lower appellate authority erred in sustaining surcharge at 25%. The order of the CIT(A) was set aside and the assessee's claim was accepted.
For private discretionary trusts whose income is chargeable at the maximum marginal rate, surcharge on income tax is to be computed by reference to the slab rates prescribed in the Finance Act for the relevant year. Applying the Special Bench ruling in Aradhya Jain Trust, the ITAT held that the assessee correctly claimed surcharge at 15% and that the lower appellate authority erred in sustaining surcharge at 25%. The order of the CIT(A) was set aside and the assessee's claim was accepted.
Note: It is a system-generated summary and is for quick reference only.