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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Exemption under section 54B requires proof of actual agricultural use of the land during the prescribed period; mere classification in revenue records is insufficient. The Tribunal found that revised 7/12 extracts could only raise a presumption and were not conclusive without corroborative evidence such as produce sale bills, seed or fertiliser purchase records, labour records, or other material showing active cultivation. As no such evidence was produced, the essential statutory condition remained unproved and the denial of exemption was upheld, with the addition sustained. The Tribunal also distinguished the cited contrary precedent on facts and relied on authority holding that revenue entries alone do not establish agricultural use.
Exemption under section 54B requires proof of actual agricultural use of the land during the prescribed period; mere classification in revenue records is insufficient. The Tribunal found that revised 7/12 extracts could only raise a presumption and were not conclusive without corroborative evidence such as produce sale bills, seed or fertiliser purchase records, labour records, or other material showing active cultivation. As no such evidence was produced, the essential statutory condition remained unproved and the denial of exemption was upheld, with the addition sustained. The Tribunal also distinguished the cited contrary precedent on facts and relied on authority holding that revenue entries alone do not establish agricultural use.
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