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...
Expenditure on software license fees paid periodically is revenue in nature and should be allowed as deduction. No disallowance u/r 8D(2)(ii) warranted when own funds exceed tax-free investments. Disallowance u/r 8D(2)(iii) to be recomputed considering only investments earning tax-free income, excluding growth funds, and suo moto disallowance by assessee. Issue of unutilized MODVAT credit restored to AO for denovo determination as per amended section 145A. Providing counter-guarantee to AE is an international transaction; ALP to be calculated at 0.5%. Delay in receipt of receivables from AE is an international transaction; interest to be charged at LIBOR+100 basis points after 60 days credit period. Provision for warranty remitted to AO to examine basis, actual expenditure, and allow as per law. Amalgamation expenses u/s 35DD restricted to 1/5th deduction for 5 years from year of amalgamation. TDS issue u/s 194H on commission payable to MD remitted to AO for denovo verification.
Expenditure on software license fees paid periodically is revenue in nature and should be allowed as deduction. No disallowance u/r 8D(2)(ii) warranted when own funds exceed tax-free investments. Disallowance u/r 8D(2)(iii) to be recomputed considering only investments earning tax-free income, excluding growth funds, and suo moto disallowance by assessee. Issue of unutilized MODVAT credit restored to AO for denovo determination as per amended section 145A. Providing counter-guarantee to AE is an international transaction; ALP to be calculated at 0.5%. Delay in receipt of receivables from AE is an international transaction; interest to be charged at LIBOR+100 basis points after 60 days credit period. Provision for warranty remitted to AO to examine basis, actual expenditure, and allow as per law. Amalgamation expenses u/s 35DD restricted to 1/5th deduction for 5 years from year of amalgamation. TDS issue u/s 194H on commission payable to MD remitted to AO for denovo verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
