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 upheld the Assessing Officer's rectification order regarding interest calculation under Section 234A(1)(a). The assessee failed to file returns by the due date of September 30, 2011, and only submitted returns on May 10, 2018, following a Section 148 notice. The period of default was correctly revised from one month to eighty months. Interest was chargeable for every month or part thereof from the day after the due date until the actual filing date. The Tribunal confirmed the AO's computation was in accordance with statutory provisions, finding no grounds for interference with the rectification order. The appeal was dismissed with costs against the assessee.
ITAT upheld the Assessing Officer's rectification order regarding interest calculation under Section 234A(1)(a). The assessee failed to file returns by the due date of September 30, 2011, and only submitted returns on May 10, 2018, following a Section 148 notice. The period of default was correctly revised from one month to eighty months. Interest was chargeable for every month or part thereof from the day after the due date until the actual filing date. The Tribunal confirmed the AO's computation was in accordance with statutory provisions, finding no grounds for interference with the rectification order. The appeal was dismissed with costs against the assessee.
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