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 overturned the CIT(A)'s finding that the Provision for Claim Pay Out was created on an adhoc basis. The Tribunal determined that the assessee had established an ascertained liability based on an independent actuarial report, considering the Trust Deed, Scheme, and applicable agreement provisions. The provision created for AY 2019-2020 was less than the actual pay out, with only a 2.21% aggregate difference between provisions and actual payouts from AY 2016-2017 to AY 2022-2023. The assessee has since been granted tax exemption under s.10(46B) by the Finance Act, 2023. The ITAT directed the AO to grant deduction for the Provision for Claim Pay Out created during the relevant previous year. Appeal allowed.
ITAT overturned the CIT(A)'s finding that the Provision for Claim Pay Out was created on an adhoc basis. The Tribunal determined that the assessee had established an ascertained liability based on an independent actuarial report, considering the Trust Deed, Scheme, and applicable agreement provisions. The provision created for AY 2019-2020 was less than the actual pay out, with only a 2.21% aggregate difference between provisions and actual payouts from AY 2016-2017 to AY 2022-2023. The assessee has since been granted tax exemption under s.10(46B) by the Finance Act, 2023. The ITAT directed the AO to grant deduction for the Provision for Claim Pay Out created during the relevant previous year. Appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
