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 foreign exchange fluctuation loss on sale proceeds held in the EEFC account - ITAT deleted addition - The High Court, after considering the arguments presented by both parties and referring to the Woodward Governor India case, concluded that the treatment of forex losses should adhere to the principles laid down in income tax law and accounting standards. It emphasized that such losses are considered as an item of expenditure under Section 37(1) of the Income Tax Act. As the issues raised had already been settled by precedent decisions, the Court declined to admit the appeal, affirming the decisions of the ITAT and the coordinate Bench of the Court.
Disallowance of foreign exchange fluctuation loss on sale proceeds held in the EEFC account - ITAT deleted addition - The High Court, after considering the arguments presented by both parties and referring to the Woodward Governor India case, concluded that the treatment of forex losses should adhere to the principles laid down in income tax law and accounting standards. It emphasized that such losses are considered as an item of expenditure under Section 37(1) of the Income Tax Act. As the issues raised had already been settled by precedent decisions, the Court declined to admit the appeal, affirming the decisions of the ITAT and the coordinate Bench of the Court.
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TaxTMI 
TaxTMI 
of 4918 
