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...
Common area maintenance charges paid under separate service arrangements were treated as contractual payments, not rent, because they did not represent consideration for use of land, building or premises. The Tribunal followed its earlier co-ordinate Bench view and held that TDS was correctly deducted under section 194C on maintenance services, not under section 194I. The Revenue's short-deduction demand under sections 201(1) and 201(1A) therefore did not survive, and the relief granted by the CIT(A) was upheld for all three assessment years.
Common area maintenance charges paid under separate service arrangements were treated as contractual payments, not rent, because they did not represent consideration for use of land, building or premises. The Tribunal followed its earlier co-ordinate Bench view and held that TDS was correctly deducted under section 194C on maintenance services, not under section 194I. The Revenue's short-deduction demand under sections 201(1) and 201(1A) therefore did not survive, and the relief granted by the CIT(A) was upheld for all three assessment years.
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