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 ruled on multiple issues in a tax appeal. Interest paid on late TDS deposits under s.201(1A) was held non-deductible as it neither qualifies as business expenditure nor compensatory payment. Regarding additions in unabated assessment years during search proceedings, following SC precedent in Abhisar Buildwell, additions were deleted due to lack of incriminating material. Notice under s.153C was upheld valid as search warrant and panchnama were not issued in assessee's name. Addition under s.69C was deleted as CIT(A) found sufficient opening cash balance as of 01.04.2017 to justify transactions, and AO failed to prove actual cash payments versus mere projections.
ITAT ruled on multiple issues in a tax appeal. Interest paid on late TDS deposits under s.201(1A) was held non-deductible as it neither qualifies as business expenditure nor compensatory payment. Regarding additions in unabated assessment years during search proceedings, following SC precedent in Abhisar Buildwell, additions were deleted due to lack of incriminating material. Notice under s.153C was upheld valid as search warrant and panchnama were not issued in assessee's name. Addition under s.69C was deleted as CIT(A) found sufficient opening cash balance as of 01.04.2017 to justify transactions, and AO failed to prove actual cash payments versus mere projections.
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