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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT quashed the reassessment proceedings u/s 148 as being bad in law, holding that the reasons recorded did not demonstrate any failure by the assessee to disclose true facts, and it was a case of "change of opinion" or "review of the assessment order" which is impermissible. The ITAT allowed the claim for deduction of reinsurance premiums paid to non-residents, depreciation on UPS at 60%, and payments made to motor vehicle dealers for services rendered. It upheld the disallowance of depreciation on projectors and addition of long-term insurance premiums received. The ITAT allowed deduction for IBNR and IBNER provisions, and held Section 14A disallowance inapplicable to insurance companies. It remitted the issue of disallowance of UPR for re-adjudication, deleted the addition u/s 14A for computing book profits, and dismissed the claim for deduction of education cess.
The ITAT quashed the reassessment proceedings u/s 148 as being bad in law, holding that the reasons recorded did not demonstrate any failure by the assessee to disclose true facts, and it was a case of "change of opinion" or "review of the assessment order" which is impermissible. The ITAT allowed the claim for deduction of reinsurance premiums paid to non-residents, depreciation on UPS at 60%, and payments made to motor vehicle dealers for services rendered. It upheld the disallowance of depreciation on projectors and addition of long-term insurance premiums received. The ITAT allowed deduction for IBNR and IBNER provisions, and held Section 14A disallowance inapplicable to insurance companies. It remitted the issue of disallowance of UPR for re-adjudication, deleted the addition u/s 14A for computing book profits, and dismissed the claim for deduction of education cess.
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