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    Section 54 exemption turns on timely reinvestment, not mere non-deposit in the Capital Gain Deposit Scheme.
    Permanent establishment under the India-Canada DTAA was rejected where remote services and short site visits failed the treaty tests.
    Reopening beyond four years fails where the AO relies on material already examined, making it a change of opinion.
    Unexplained cash credit addition deleted where NBFC lender's identity, creditworthiness and loan genuineness were already accepted on identical facts.
    Mechanical sanction for reassessment invalidates jurisdiction where approval under section 151 is recorded only as "Yes".
    Reassessment limitation under section 149(1)(b) failed where statutory threshold material was absent and the 148A(d) order lacked reasons.
    Exclusive accounting and double taxation rules led to deletion of indirect tax refund additions and recomputation of interest.
    Registration under section 12AB cannot be refused for alleged section 13 violations; such issues belong in assessment.
    Section 68 cash sales accepted, but alleged gifted capital failed for lack of proper verification and remand followed.
    Section 80P deduction barred by belated return after section 80AC substitution, with denial sustained.
    Rule 46A and section 69A: demonetisation cash deposits explained from existing books, so addition was deleted.
    Transfer pricing adjustment: Bright Line Test rejected, royalty issues treated as covered, and comparable exclusion found factual.
    Stamp duty valuation governed reassessment limitation, and the extended period applied because the petitioner's share crossed the threshold.
    Reassessment limitation upheld where response time was excluded under section 149 and survey material qualified as an asset.
    Peak credit, TDS disallowance and work-in-progress adjustments shaped the tribunal's tax rulings on business receipts.
    Treaty benefit for separate capital gains sources allowed; DTAA-exempt share gains cannot be forced into Act-based loss set-off.
    TNMM transfer pricing principles reshape comparables, working capital, royalty, services and receivables adjustments in a mixed ITAT ruling.
    Deduction for standard-asset provisioning under section 36(1)(viia) allowed where RBI norms are followed and books reflect the provision.
    Beneficial leave-encashment exemption amendment applied retrospectively to pending matters, extending the higher ceiling.
    Bona fide share transfer to wholly owned subsidiary qualifies for section 47(iv) exemption despite tax benefit.
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Acts Income Tax