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...
Receipt on premature surrender of a pension policy was held to require examination under section 80CCC(2) in light of the true nature of the amount received. The Tribunal found that the Assessing Officer had taxed it as income from other sources without properly considering the statutory provision, the factual matrix, or the assessee's submissions and documentary evidence. As the reassessment and addition were made without due legal appreciation, the addition was directed to be deleted and the appeal was allowed.
Receipt on premature surrender of a pension policy was held to require examination under section 80CCC(2) in light of the true nature of the amount received. The Tribunal found that the Assessing Officer had taxed it as income from other sources without properly considering the statutory provision, the factual matrix, or the assessee's submissions and documentary evidence. As the reassessment and addition were made without due legal appreciation, the addition was directed to be deleted and the appeal was allowed.
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