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...
The ITAT dismissed the revenue's appeals and upheld the CIT(A)'s order deleting the additions made by the AO. The assessee provided invoices and documents proving the purchases, which were accepted in the remand report. The 10% disallowance of other expenses was deleted after the AO verified the invoices. The disallowance of foreign exchange loss was rejected, relying on precedents that the revenue cannot question the commercial expediency of business expenditure if the nexus with business is established.
The ITAT dismissed the revenue's appeals and upheld the CIT(A)'s order deleting the additions made by the AO. The assessee provided invoices and documents proving the purchases, which were accepted in the remand report. The 10% disallowance of other expenses was deleted after the AO verified the invoices. The disallowance of foreign exchange loss was rejected, relying on precedents that the revenue cannot question the commercial expediency of business expenditure if the nexus with business is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
