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...
Adjustment of part income-tax refund received by the assessee against the total outstanding refund, comprising of principal/ tax and interest - quantum of interest to which the assessee would be entitled u/s 244A - The Tribunal concluded that the part refund should first be adjusted against the interest component of the outstanding refund before adjusting against the principal. This decision aligns with previous rulings from various ITAT benches and the principles of fairness, equity, and good conscience. - The Tribunal discredited the Revenue's argument that this adjustment method would result in granting interest on interest, which is not permissible. It underscored that the adjustment strategy proposed by the assessee does not infringe upon the principles laid down by the Supreme Court.
Adjustment of part income-tax refund received by the assessee against the total outstanding refund, comprising of principal/ tax and interest - quantum of interest to which the assessee would be entitled u/s 244A - The Tribunal concluded that the part refund should first be adjusted against the interest component of the outstanding refund before adjusting against the principal. This decision aligns with previous rulings from various ITAT benches and the principles of fairness, equity, and good conscience. - The Tribunal discredited the Revenue's argument that this adjustment method would result in granting interest on interest, which is not permissible. It underscored that the adjustment strategy proposed by the assessee does not infringe upon the principles laid down by the Supreme Court.
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TaxTMI 
TaxTMI 
of 4918 
