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 as per order u/s 144C - default in filling of form 35A - The appellant filed a corrected Form No. 35A. The Tribunal ruled that this correction did not constitute filing beyond the time limit, and thus upheld the appellant's contention. - On the issue of disallowed expenses, the Tribunal noted that the appellant had provided sufficient evidence to demonstrate the legitimacy of the claimed expenses related to the sale of a residential property. The assessing officer's rejection of these expenses solely based on procedural grounds was deemed unjustified. Consequently, the Tribunal directed the assessing officer to review the supporting documents and allow the expenses accordingly.
Disallowance as per order u/s 144C - default in filling of form 35A - The appellant filed a corrected Form No. 35A. The Tribunal ruled that this correction did not constitute filing beyond the time limit, and thus upheld the appellant's contention. - On the issue of disallowed expenses, the Tribunal noted that the appellant had provided sufficient evidence to demonstrate the legitimacy of the claimed expenses related to the sale of a residential property. The assessing officer's rejection of these expenses solely based on procedural grounds was deemed unjustified. Consequently, the Tribunal directed the assessing officer to review the supporting documents and allow the expenses accordingly.
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TaxTMI 
TaxTMI 
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