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 reversed CPC's disallowance of IPO expenditure under s.37 where variation existed between Form 3CD and ITR values. Following Kalpesh Synthetics precedent, ITAT held that disallowance cannot be made solely based on tax audit report observations. The tribunal directed deletion of IPO cost disallowance under s.37(1). On DDT credit under s.115-O, matter remanded to AO for verification and appropriate credit determination after providing opportunity of hearing to assessee. AO directed to follow due process and decide based on facts and applicable law.
ITAT reversed CPC's disallowance of IPO expenditure under s.37 where variation existed between Form 3CD and ITR values. Following Kalpesh Synthetics precedent, ITAT held that disallowance cannot be made solely based on tax audit report observations. The tribunal directed deletion of IPO cost disallowance under s.37(1). On DDT credit under s.115-O, matter remanded to AO for verification and appropriate credit determination after providing opportunity of hearing to assessee. AO directed to follow due process and decide based on facts and applicable law.
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