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...
Section 56(2)(x) was treated as inapplicable where land was acquired solely through purchase of leasehold rights rather than ownership rights in land. The interpretation followed co-ordinate Tribunal decisions that compared the provision with Section 50C and adopted the view favourable to the assessee amid conflicting High Court views. Characterising the transaction as a sale of land did not change its legal character as a transfer of leasehold rights. The related addition was deleted.
Section 56(2)(x) was treated as inapplicable where land was acquired solely through purchase of leasehold rights rather than ownership rights in land. The interpretation followed co-ordinate Tribunal decisions that compared the provision with Section 50C and adopted the view favourable to the assessee amid conflicting High Court views. Characterising the transaction as a sale of land did not change its legal character as a transfer of leasehold rights. The related addition was deleted.
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TaxTMI 
TaxTMI 
of 4918 
