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 ruled against PCIT's interpretation of depreciation computation under Section 32(1)(ii) and 43(6)(c). The tribunal rejected PCIT's method requiring brought forward additional depreciation from AY 2017-18 to be first reduced from opening WDV before computing current year's depreciation for AY 2018-19. ITAT affirmed depreciation must be calculated on WDV of block assets per prescribed rates, with WDV computation only adjusted for asset additions and disposals during the year. The tribunal found assessee's depreciation claim aligned with ITR utility format and Tax Audit Report requirements. Since no erroneous treatment prejudicial to revenue interest was established, assessee's appeal was allowed, invalidating revision under s.263.
ITAT ruled against PCIT's interpretation of depreciation computation under Section 32(1)(ii) and 43(6)(c). The tribunal rejected PCIT's method requiring brought forward additional depreciation from AY 2017-18 to be first reduced from opening WDV before computing current year's depreciation for AY 2018-19. ITAT affirmed depreciation must be calculated on WDV of block assets per prescribed rates, with WDV computation only adjusted for asset additions and disposals during the year. The tribunal found assessee's depreciation claim aligned with ITR utility format and Tax Audit Report requirements. Since no erroneous treatment prejudicial to revenue interest was established, assessee's appeal was allowed, invalidating revision under s.263.
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