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...
Foreign contribution disclosed in the books and in the return of income could not be taxed merely because it was entered in Schedule-AI instead of Schedule-VC. The Tribunal held that there was no suppression of receipt, and the defect was only an inadvertent disclosure error in the wrong schedule. Denial of the charitable exemption claim solely on the ground that a revised return was not filed was unsustainable. The Revenue cannot collect tax beyond what is lawfully due merely because of an assessee's mistake in reporting. The impugned addition was deleted.
Foreign contribution disclosed in the books and in the return of income could not be taxed merely because it was entered in Schedule-AI instead of Schedule-VC. The Tribunal held that there was no suppression of receipt, and the defect was only an inadvertent disclosure error in the wrong schedule. Denial of the charitable exemption claim solely on the ground that a revised return was not filed was unsustainable. The Revenue cannot collect tax beyond what is lawfully due merely because of an assessee's mistake in reporting. The impugned addition was deleted.
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