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...
Deduction under Chapter VIA for new employment could not be denied merely because Form No. 10DA was filed belatedly. The Tribunal treated the form-filing requirement as procedural, not substantive, and followed its earlier view that delay in furnishing the form does not defeat an otherwise admissible claim where no contrary material is shown. As the facts and grounds were identical for both assessment years, the same relief applied in each year. The appellate order was set aside and the Assessing Officer/CPC was directed to allow the deduction as claimed.
Deduction under Chapter VIA for new employment could not be denied merely because Form No. 10DA was filed belatedly. The Tribunal treated the form-filing requirement as procedural, not substantive, and followed its earlier view that delay in furnishing the form does not defeat an otherwise admissible claim where no contrary material is shown. As the facts and grounds were identical for both assessment years, the same relief applied in each year. The appellate order was set aside and the Assessing Officer/CPC was directed to allow the deduction as claimed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
