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...
Disallowance of TDS on account of mismatch & later on TDS matched but AO not given credit - Although the rectification application was filed beyond the permissible time limit, the Tribunal invoked Section 155, which empowers the AO to rectify apparent errors in credit of taxes. Considering the appellant's efforts to rectify the TDS credit and the genuineness of the tax credit denied by the AO, the Tribunal directed the AO to pass a consequential order granting the tax credit due to the appellant.
Disallowance of TDS on account of mismatch & later on TDS matched but AO not given credit - Although the rectification application was filed beyond the permissible time limit, the Tribunal invoked Section 155, which empowers the AO to rectify apparent errors in credit of taxes. Considering the appellant's efforts to rectify the TDS credit and the genuineness of the tax credit denied by the AO, the Tribunal directed the AO to pass a consequential order granting the tax credit due to the appellant.
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