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 ruled on two issues: 1. Disallowance of Business Promotion Expenses: AO disallowed expenses for a get-together, citing lack of proof of business purpose. CIT(A) upheld, but ITAT found the expenses legitimate due to revenue from operations, accepted expenses, and TDS payment to caterer. AO's disallowance was deemed incorrect. 2. Cessation of Liability u/s 41(1): AO added outstanding professional fees as income u/s 41(1) for being unpaid over 3 years. ITAT disagreed, noting the liability in financial statements indicates intent to settle. Addition was deemed incorrect, and AO was directed to delete it. Assessee's appeal was allowed.
The ITAT ruled on two issues: 1. Disallowance of Business Promotion Expenses: AO disallowed expenses for a get-together, citing lack of proof of business purpose. CIT(A) upheld, but ITAT found the expenses legitimate due to revenue from operations, accepted expenses, and TDS payment to caterer. AO's disallowance was deemed incorrect. 2. Cessation of Liability u/s 41(1): AO added outstanding professional fees as income u/s 41(1) for being unpaid over 3 years. ITAT disagreed, noting the liability in financial statements indicates intent to settle. Addition was deemed incorrect, and AO was directed to delete it. Assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
