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 allowed the assessee's appeal regarding foreign tax credit for state taxes paid in the United States under Section 91, despite the existence of an India-USA DTAA. The Tribunal rejected Revenue's contentions, noting that the issue was no longer res integra following the Karnataka HC decision in Wipro Ltd., which established that both federal and state taxes stand on equal footing for foreign tax credit claims. Although Revenue cited a contrary ITAT Delhi ruling in Manpreet Singh Gambhir, the Tribunal held that judicial discipline required following the higher judicial forum's decision. The AO was directed to compute the consequential relief accordingly.
The ITAT allowed the assessee's appeal regarding foreign tax credit for state taxes paid in the United States under Section 91, despite the existence of an India-USA DTAA. The Tribunal rejected Revenue's contentions, noting that the issue was no longer res integra following the Karnataka HC decision in Wipro Ltd., which established that both federal and state taxes stand on equal footing for foreign tax credit claims. Although Revenue cited a contrary ITAT Delhi ruling in Manpreet Singh Gambhir, the Tribunal held that judicial discipline required following the higher judicial forum's decision. The AO was directed to compute the consequential relief accordingly.
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TaxTMI 
TaxTMI 
of 4918 
