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 partially allowed the appellant's appeal against revision proceedings under section 263. Regarding excess deduction under section 35CCC, the Tribunal upheld the revision but modified the disallowance amount to INR 8,03,76,735 instead of INR 10,68,11,066 as directed by PCIT. On the section 14A disallowance issue, ITAT found that the AO had properly examined the matter during assessment proceedings, making revision unwarranted. The Tribunal noted that CBDT Circular No. 5 of 2014 was inapplicable as the appellant had actually earned exempt dividend income. Similarly, regarding depreciation on land value, ITAT held that the AO had made proper inquiry after considering the appellant's submissions and litigation history.
ITAT partially allowed the appellant's appeal against revision proceedings under section 263. Regarding excess deduction under section 35CCC, the Tribunal upheld the revision but modified the disallowance amount to INR 8,03,76,735 instead of INR 10,68,11,066 as directed by PCIT. On the section 14A disallowance issue, ITAT found that the AO had properly examined the matter during assessment proceedings, making revision unwarranted. The Tribunal noted that CBDT Circular No. 5 of 2014 was inapplicable as the appellant had actually earned exempt dividend income. Similarly, regarding depreciation on land value, ITAT held that the AO had made proper inquiry after considering the appellant's submissions and litigation history.
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TaxTMI 
TaxTMI 
of 4918 
