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...
ITAT addressed multiple issues in a transfer pricing and tax deduction appeal. On interest-free loans to AE, the matter was remanded for verification of surplus funds and nexus with borrowed loans. Corporate guarantee fee was benchmarked at 0.5%. Depreciation on leasehold property rights was remitted following Madras HC precedent. Section 80G deduction for CSR expenses was remanded for de novo consideration. Section 14A disallowance was directed to consider only investments yielding exempt income. TP adjustment on debenture interest was to be benchmarked based on comparable international transactions at 1.76% rather than domestic rates. The appeal was partly allowed with specific directions for reassessment of each issue according to prescribed parameters.
ITAT addressed multiple issues in a transfer pricing and tax deduction appeal. On interest-free loans to AE, the matter was remanded for verification of surplus funds and nexus with borrowed loans. Corporate guarantee fee was benchmarked at 0.5%. Depreciation on leasehold property rights was remitted following Madras HC precedent. Section 80G deduction for CSR expenses was remanded for de novo consideration. Section 14A disallowance was directed to consider only investments yielding exempt income. TP adjustment on debenture interest was to be benchmarked based on comparable international transactions at 1.76% rather than domestic rates. The appeal was partly allowed with specific directions for reassessment of each issue according to prescribed parameters.
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TaxTMI 
TaxTMI 
of 4918 
