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...
TDS u/s 195 and disallowance u/s 40(a)(ia) towards sales commission paid were challenged. Since the services rendered did not fall within fees for technical services or Article 12 of the tax treaty, the assessee contended no TDS obligation existed. Following the coordinate bench's decision in the assessee's own case for prior years, it was held that no infirmity existed in the CIT(A)'s order, and no disallowance u/s 40(a)(i) was warranted. Regarding ESOP expenses, the issue's allowability is well-settled. Consistently, the coordinate bench in the assessee's case for prior years allowed ESOP expenses as a deduction. Hence, the CIT(A)'s decision allowing the ESOP expenses claim was upheld. The matter was decided in favor of the assessee.
TDS u/s 195 and disallowance u/s 40(a)(ia) towards sales commission paid were challenged. Since the services rendered did not fall within fees for technical services or Article 12 of the tax treaty, the assessee contended no TDS obligation existed. Following the coordinate bench's decision in the assessee's own case for prior years, it was held that no infirmity existed in the CIT(A)'s order, and no disallowance u/s 40(a)(i) was warranted. Regarding ESOP expenses, the issue's allowability is well-settled. Consistently, the coordinate bench in the assessee's case for prior years allowed ESOP expenses as a deduction. Hence, the CIT(A)'s decision allowing the ESOP expenses claim was upheld. The matter was decided in favor of the assessee.
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