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...
The ITAT ruled that expenses related to an aborted Initial Public Offering (IPO) are deductible under s.37 of the Income Tax Act, following the precedent set in Nimbus Communication Ltd. While share issue expenses are generally capital in nature and non-deductible under s.37 (except as permitted under s.35D), the Tribunal distinguished between completed and abandoned capital projects. The ITAT held that aborted share issue expenses qualify for business deduction, setting aside the CIT(A)'s finding and directing the Assessing Officer to delete the addition to the extent related to the assessee's equity base increase, excluding expenses pertaining to the Offer For Sale (OFS) by promoters. The assessee's appeal was allowed.
The ITAT ruled that expenses related to an aborted Initial Public Offering (IPO) are deductible under s.37 of the Income Tax Act, following the precedent set in Nimbus Communication Ltd. While share issue expenses are generally capital in nature and non-deductible under s.37 (except as permitted under s.35D), the Tribunal distinguished between completed and abandoned capital projects. The ITAT held that aborted share issue expenses qualify for business deduction, setting aside the CIT(A)'s finding and directing the Assessing Officer to delete the addition to the extent related to the assessee's equity base increase, excluding expenses pertaining to the Offer For Sale (OFS) by promoters. The assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
