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...
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
