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...
Various disallowances and additions made by the Assessing Officer (AO) and the Income Tax Appellate Tribunal's (ITAT) decisions on the same. The key points are: 1) Disallowance u/s 40(a)(ia) for non-deduction of TDS on ocean freight charges was deleted, as per CBDT circular, neither Section 194C nor 195 is applicable to such payments. 2) Disallowance of entire traveling expenses was restricted to 25% as no proof of business purpose was provided. 3) Addition u/s 41(1) for outstanding sundry creditors was deleted as the amount was offered to tax in the subsequent year, avoiding double taxation. 4) Disallowance of motor car expenses and depreciation was restricted to 10% for personal use, following judicial precedents. 5) Disallowance of excess interest payment u/s 40A(2)(b) was deleted, relying on the Gujarat High Court decision.
Various disallowances and additions made by the Assessing Officer (AO) and the Income Tax Appellate Tribunal's (ITAT) decisions on the same. The key points are: 1) Disallowance u/s 40(a)(ia) for non-deduction of TDS on ocean freight charges was deleted, as per CBDT circular, neither Section 194C nor 195 is applicable to such payments. 2) Disallowance of entire traveling expenses was restricted to 25% as no proof of business purpose was provided. 3) Addition u/s 41(1) for outstanding sundry creditors was deleted as the amount was offered to tax in the subsequent year, avoiding double taxation. 4) Disallowance of motor car expenses and depreciation was restricted to 10% for personal use, following judicial precedents. 5) Disallowance of excess interest payment u/s 40A(2)(b) was deleted, relying on the Gujarat High Court decision.
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