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...
Framing assessment u/s 143(3) without serving notices at the registered e-mail address - changing of the e-mail id - The ITAT found that the appellant had not communicated their change in email address to the revenue authorities, hence dismissing the appellant's claim of non-service of notices. - Concerning the disallowance of exceptional items, the tribunal determined that the shares issued by RFCL to the appellant constituted income, earned in exchange for the right to use the appellant's capital asset. Therefore, the disallowance made by the Assessing Officer was upheld. The tribunal directed the deletion of any income already offered for taxation in subsequent years to avoid double taxation.
Framing assessment u/s 143(3) without serving notices at the registered e-mail address - changing of the e-mail id - The ITAT found that the appellant had not communicated their change in email address to the revenue authorities, hence dismissing the appellant's claim of non-service of notices. - Concerning the disallowance of exceptional items, the tribunal determined that the shares issued by RFCL to the appellant constituted income, earned in exchange for the right to use the appellant's capital asset. Therefore, the disallowance made by the Assessing Officer was upheld. The tribunal directed the deletion of any income already offered for taxation in subsequent years to avoid double taxation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
