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...
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The Appellate Tribunal considered various issues. Firstly, on disallowance u/s. 14A r.w. Rule 8D(ii), it was held that no disallowance of interest expenditure was warranted as the company had sufficient interest-free funds to source its investments in exempt income-yielding shares. The Tribunal referred to relevant case law to support this decision. Secondly, on addition towards various expenses, the Tribunal upheld the CIT(Appeals) decision to allow deduction under section 37 of the Act as the Assessing Officer failed to provide justifiable reasons for disallowance. Lastly, on addition u/s 68 for unexplained loan transaction, the Tribunal concurred with the CIT(Appeals) that the loan raised from a lender company was not unexplained cash credit as the identity of the lender was proven. The Tribunal dismissed the revenue's appeals on all grounds.
The Appellate Tribunal considered various issues. Firstly, on disallowance u/s. 14A r.w. Rule 8D(ii), it was held that no disallowance of interest expenditure was warranted as the company had sufficient interest-free funds to source its investments in exempt income-yielding shares. The Tribunal referred to relevant case law to support this decision. Secondly, on addition towards various expenses, the Tribunal upheld the CIT(Appeals) decision to allow deduction under section 37 of the Act as the Assessing Officer failed to provide justifiable reasons for disallowance. Lastly, on addition u/s 68 for unexplained loan transaction, the Tribunal concurred with the CIT(Appeals) that the loan raised from a lender company was not unexplained cash credit as the identity of the lender was proven. The Tribunal dismissed the revenue's appeals on all grounds.
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