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    Revisional relief for omitted charitable-trust capital-gains claims extends to fixed-deposit reinvestment where disclosure was complete.
    Subsisting reasons to believe fail when appellate relief removes every subsequent-year foundation for reassessment; the notice was quashed.
    Reason to believe in reassessment requires a live material nexus; unrelated allegations and later law cannot sustain reopening.
    Draft assessment procedure requires eligible-assessee status and final determination before demand or penalty notices can validly issue.
    Signed statutory approval is essential for reassessment jurisdiction; electronic authentication cannot replace a manual or digital signature.
    Intra-group service pricing adjustment deleted after arm's length price was set at nil without sustainable basis.
    Transfer-pricing benchmarking requires proven COVID costs, consistent TNMM classifications, and reliable internal CUP comparability before adjustments...
    Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
    Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
    Transfer-pricing comparability requires aligned related-party exposure, ownership profile, revenue model and sourcing-support functions to prevent dis...
    Assessment jurisdiction requires valid statutory transfer and timely scrutiny notice; administrative reassignment cannot sustain proceedings.
    TDS on statutory market fees and pass-through procurement payments did not trigger contract withholding disallowance.
    Binding Dispute Resolution Panel directions invalidate non-conforming assessments, while ad hoc nil pricing of intra-group services fails.
    Electronic service of DRP directions triggers assessment limitation, making a belated final assessment time-barred and beyond jurisdiction.
    TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
    Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
    Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
    Misreporting penalties require proven statutory defaults, not merely transfer-pricing adjustments caused by competing benchmarking and comparability m...
    Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
    Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Acts Income Tax