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...
Transfer pricing adjustment on export commission paid to related party disallowed based on assessee's own case demonstrating benefits and higher profitability. Royalty payment to related party allowed as deduction following earlier year's order. Signage expenses at dealers' premises allowed as revenue expenditure based on Supreme Court ruling. Sales tools expenses allowed as revenue expenditure following coordinate bench order. Part capitalization of royalty expenses disallowed following Tribunal's consistent view in earlier years. Disallowance of education cess upheld based on Supreme Court ruling and retrospective amendment. Excess dividend distribution tax refund claim restored to Assessing Officer for adjudication considering assessee's submissions. Technical know-how expenses disallowance restored to Assessing Officer for fresh adjudication giving reasonable opportunity to assessee, as claim allowed in earlier years.
Transfer pricing adjustment on export commission paid to related party disallowed based on assessee's own case demonstrating benefits and higher profitability. Royalty payment to related party allowed as deduction following earlier year's order. Signage expenses at dealers' premises allowed as revenue expenditure based on Supreme Court ruling. Sales tools expenses allowed as revenue expenditure following coordinate bench order. Part capitalization of royalty expenses disallowed following Tribunal's consistent view in earlier years. Disallowance of education cess upheld based on Supreme Court ruling and retrospective amendment. Excess dividend distribution tax refund claim restored to Assessing Officer for adjudication considering assessee's submissions. Technical know-how expenses disallowance restored to Assessing Officer for fresh adjudication giving reasonable opportunity to assessee, as claim allowed in earlier years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
