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...
Credit of TDS - consideration received for offshore supply of rolling stock, when no corresponding income has been offered for taxation by the assessee - The ITAT cited precedent to assert that TDS credit should be granted regardless of whether the income was directly offered for taxation, as long as TDS was deducted and deposited with the government. - The Tribunal upheld the assessee's entitlement to TDS credit and subsequent refunds, in alignment with previous rulings and provisions of the Income Tax Act.
Credit of TDS - consideration received for offshore supply of rolling stock, when no corresponding income has been offered for taxation by the assessee - The ITAT cited precedent to assert that TDS credit should be granted regardless of whether the income was directly offered for taxation, as long as TDS was deducted and deposited with the government. - The Tribunal upheld the assessee's entitlement to TDS credit and subsequent refunds, in alignment with previous rulings and provisions of the Income Tax Act.
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