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, an Appellate Tribunal, considered a case involving a penalty u/s 271(1)(c) for a difference in depreciation treatment of a biometric device. The issue was whether the device should be classified under 'Plant and Machinery' or 'Computer' block for depreciation. The ITAT found the claim was not false but a matter of interpretation. Merely disagreeing with the claim does not warrant a penalty if the assessee provided all relevant details. Citing a precedent from Reliance Petro Products Pvt. Ltd, the ITAT ruled in favor of the assessee, deleting the penalty imposed by the Assessing Officer.
The ITAT, an Appellate Tribunal, considered a case involving a penalty u/s 271(1)(c) for a difference in depreciation treatment of a biometric device. The issue was whether the device should be classified under 'Plant and Machinery' or 'Computer' block for depreciation. The ITAT found the claim was not false but a matter of interpretation. Merely disagreeing with the claim does not warrant a penalty if the assessee provided all relevant details. Citing a precedent from Reliance Petro Products Pvt. Ltd, the ITAT ruled in favor of the assessee, deleting the penalty imposed by the Assessing Officer.
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