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...
Depreciation claim disallowance u/s 40(a)(i) for failure to deduct TDS on capitalized software payments is disallowed, following coordinate bench decision. Addition u/s 28(iv) for assets received free of cost from AEs for testing purposes is rejected, as assets are temporary, returned/destroyed after testing, pricing agreed under MAP embeds indirect benefits, and billing is cost-plus basis, precluding separate addition u/s 28(iv). Assessee's grounds allowed, revenue's appeal dismissed.
Depreciation claim disallowance u/s 40(a)(i) for failure to deduct TDS on capitalized software payments is disallowed, following coordinate bench decision. Addition u/s 28(iv) for assets received free of cost from AEs for testing purposes is rejected, as assets are temporary, returned/destroyed after testing, pricing agreed under MAP embeds indirect benefits, and billing is cost-plus basis, precluding separate addition u/s 28(iv). Assessee's grounds allowed, revenue's appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
