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...
The ITAT quashed the CIT's revision order under section 263, finding it was improperly based solely on audit objections without independent examination of records. The Tribunal determined that the PCIT failed to establish how the AO's view was erroneous or prejudicial to revenue interests. The ITAT ruled on multiple grounds in the assessee's favor: (1) ESI/PF disallowance was improper as the AO had verified the issue was merely a grouping error; (2) excess stock was correctly treated as business income, not under section 69 read with 115BBE; (3) section 14A disallowance was invalid as the 2022 amendment was prospective; and (4) section 10AA deduction was proper as the AO had examined and verified the claim. The Tribunal emphasized that section 263 does not confer unlimited revisionary powers to the PCIT.
The ITAT quashed the CIT's revision order under section 263, finding it was improperly based solely on audit objections without independent examination of records. The Tribunal determined that the PCIT failed to establish how the AO's view was erroneous or prejudicial to revenue interests. The ITAT ruled on multiple grounds in the assessee's favor: (1) ESI/PF disallowance was improper as the AO had verified the issue was merely a grouping error; (2) excess stock was correctly treated as business income, not under section 69 read with 115BBE; (3) section 14A disallowance was invalid as the 2022 amendment was prospective; and (4) section 10AA deduction was proper as the AO had examined and verified the claim. The Tribunal emphasized that section 263 does not confer unlimited revisionary powers to the PCIT.
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