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...
Recovery of interest on the wrongly availed credit - The Tribunal upheld that interest under Rule 14 is liable on wrongly taken credit, irrespective of its utilization, aligning with the Supreme Court's interpretation in the case of Union of India Vs Ind-Swift Laboratories Ltd. Additionally, it rejected the applicability of amendment arguments regarding "substitution" in Rule 14, emphasizing strict interpretation of taxing statutes without room for implications beyond the clear statutory language.
Recovery of interest on the wrongly availed credit - The Tribunal upheld that interest under Rule 14 is liable on wrongly taken credit, irrespective of its utilization, aligning with the Supreme Court's interpretation in the case of Union of India Vs Ind-Swift Laboratories Ltd. Additionally, it rejected the applicability of amendment arguments regarding "substitution" in Rule 14, emphasizing strict interpretation of taxing statutes without room for implications beyond the clear statutory language.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
