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...
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Bank-specific tax claims were largely upheld: deduction for provision for bad and doubtful debts under section 36(1)(viia), tax treatment of unrealised foreign exchange forward contract gains, CSR expenditure, depreciation on ATMs as computers, depreciation on bank investment portfolio and leased assets, deduction for special reserve, accrual of interest on securities, and the inapplicability of minimum alternate tax to banking companies. On exempt income, the Tribunal accepted verification of own funds and recomputation of administrative disallowance for bank investments. Following binding precedent and no material factual change, the Revenue's appeal was dismissed and the appellate order was sustained on all contested issues.
Bank-specific tax claims were largely upheld: deduction for provision for bad and doubtful debts under section 36(1)(viia), tax treatment of unrealised foreign exchange forward contract gains, CSR expenditure, depreciation on ATMs as computers, depreciation on bank investment portfolio and leased assets, deduction for special reserve, accrual of interest on securities, and the inapplicability of minimum alternate tax to banking companies. On exempt income, the Tribunal accepted verification of own funds and recomputation of administrative disallowance for bank investments. Following binding precedent and no material factual change, the Revenue's appeal was dismissed and the appellate order was sustained on all contested issues.
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