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 held that TDS liability under sections 201(1) and 201(1A) regarding lease rent payments made to NOIDA was not applicable to the assessee for A.Y. 2012-13. Following precedents established in Rajesh Projects (India) Pvt. Ltd. and Mahagun (India) (P.) Ltd., the Tribunal determined that the Revenue had no cause of action under these sections for the assessment year in question. The CIT(A)'s decision to delete the TDS liability was confirmed, with the final ruling being against the Revenue.
The ITAT held that TDS liability under sections 201(1) and 201(1A) regarding lease rent payments made to NOIDA was not applicable to the assessee for A.Y. 2012-13. Following precedents established in Rajesh Projects (India) Pvt. Ltd. and Mahagun (India) (P.) Ltd., the Tribunal determined that the Revenue had no cause of action under these sections for the assessment year in question. The CIT(A)'s decision to delete the TDS liability was confirmed, with the final ruling being against the Revenue.
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TaxTMI 
TaxTMI 
of 4918 
