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    Section 87A rebate extends to long-term capital gains under section 112 absent an express statutory bar, the Tribunal holds.
    Search assessment and multiplex lease receipts: incriminating material limits additions, but commercial exploitation supported business income treatme...
    Reassessment by change of opinion fails where reopening rests on the same records and an incorrect factual premise.
    Limited scrutiny assessment cannot support additions beyond selected issues without conversion to complete scrutiny.
    Turnover filter and functional comparability in software transfer pricing upheld; limited comparables can still support arm's length benchmarking.
    Unsubstantiated commission-agent claim rejected; profit estimation from bank credits cut from 12.5% to 4% in trade income case.
    Diversion of income by overriding title shields liquidation receipts from tax where statutory application diverts realizations at source.
    Make available condition under the India-Netherlands treaty defeated FTS taxability; surcharge and cess beyond treaty rate were disallowed.
    Wilful failure to deposit TDS can sustain prosecution where notice was duly served and non-compliance continued.
    Retrospective reassessment amendment challenge remitted for fresh consideration, with liberty to contest section 147A and related provisions.
    Section 43B deduction for GST payable allowed if paid before return due date, despite audit report showing liability outstanding.
    Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
    Taxing only profit from suppressed turnover and avoiding double addition under section 69C in unaccounted sales cases
    TDS correction statements and 234E fee levy before 01.06.2015 were held unsustainable by the ITAT.
    Section 153C jurisdiction fails for pre-block year and post-2021 initiation, quashing assessments under search provisions.
    Documentary proof of loan transaction defeated unexplained cash credit addition based on suspicion and third-party information.
    Depreciation on goodwill from amalgamation remained allowable for pre-amendment years under settled law.
    Interest deduction on borrowed capital denied where funds were invested as partner's capital, not used for the assessee's own business.
    Review jurisdiction limits bar rehearing where no error apparent exists in the DTVSV Form-2 dispute.
    Transfer pricing adjustment on AMP spend deleted where no arrangement showed an international transaction with the associated enterprise.
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Acts Income Tax