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...
The ITAT allowed the assessee's appeal and deleted the disallowances made by the Assessing Officer (AO) u/s 154 read with Section 143(3) and by the CIT(A). The AO erred in passing the order u/s 154 by making the disallowance of amortization of telecom license u/s 35ABB and depreciation on right to use telecom spectrum u/s 32. The CIT(A) also erred by disallowing an amount which was not part of the appeal before them. The ITAT held that the CIT(A) exercised jurisdiction beyond the scope of the appeal by disallowing an amount which was part of separate appeal proceedings. Accordingly, the ITAT allowed the assessee's appeal and additional grounds, deleting the disallowances made by the AO and CIT(A).
The ITAT allowed the assessee's appeal and deleted the disallowances made by the Assessing Officer (AO) u/s 154 read with Section 143(3) and by the CIT(A). The AO erred in passing the order u/s 154 by making the disallowance of amortization of telecom license u/s 35ABB and depreciation on right to use telecom spectrum u/s 32. The CIT(A) also erred by disallowing an amount which was not part of the appeal before them. The ITAT held that the CIT(A) exercised jurisdiction beyond the scope of the appeal by disallowing an amount which was part of separate appeal proceedings. Accordingly, the ITAT allowed the assessee's appeal and additional grounds, deleting the disallowances made by the AO and CIT(A).
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TaxTMI 
TaxTMI 
of 4918 
