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...
Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.
Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
