Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Liquidated damages provision was disallowed as it was based on unascertained liability without probability of outflow of resources. ITAT deleted addition, holding provision arose from contractual obligation and estimation basis was reasonable based on past experience. Warranty provision at 2% of turnover based on past experience was appropriate, fulfilling accrual and matching concepts, unlike accounting expense in year incurred or on claim by customer. TPO's rectification enhancing income was void ab initio for lack of opportunity to assessee before enhancement u/s 154(3). ITAT's conclusion that services provided by AE were not stewardship services upheld. Questions 2.5 and 2.6 to be re-notified on 07.03.2024 for submissions.
Liquidated damages provision was disallowed as it was based on unascertained liability without probability of outflow of resources. ITAT deleted addition, holding provision arose from contractual obligation and estimation basis was reasonable based on past experience. Warranty provision at 2% of turnover based on past experience was appropriate, fulfilling accrual and matching concepts, unlike accounting expense in year incurred or on claim by customer. TPO's rectification enhancing income was void ab initio for lack of opportunity to assessee before enhancement u/s 154(3). ITAT's conclusion that services provided by AE were not stewardship services upheld. Questions 2.5 and 2.6 to be re-notified on 07.03.2024 for submissions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
