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...
ITAT allowed partial relief to appellant, a railway guard, regarding TDS credit denial. While non-response to notices due to frequent travel was deemed an inadequate excuse for tax non-compliance, the AO's failure to consider documented TDS credits in Form 26AS was found perverse. Matter remanded to AO for reassessment with directions to verify facts, allow legitimate TDS credits shown in Form 26AS under section 192, and consider eligible deductions under law. Tribunal emphasized that employment nature cannot justify evasive approach to tax obligations but ensured protection of substantive rights regarding documented tax deductions.
ITAT allowed partial relief to appellant, a railway guard, regarding TDS credit denial. While non-response to notices due to frequent travel was deemed an inadequate excuse for tax non-compliance, the AO's failure to consider documented TDS credits in Form 26AS was found perverse. Matter remanded to AO for reassessment with directions to verify facts, allow legitimate TDS credits shown in Form 26AS under section 192, and consider eligible deductions under law. Tribunal emphasized that employment nature cannot justify evasive approach to tax obligations but ensured protection of substantive rights regarding documented tax deductions.
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TaxTMI 
TaxTMI 
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