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...
HC held that client assistant charges paid to ICICI Bank Ltd constitute legitimate business expenditure. The court rejected revenue's disallowance of expenses, finding that: (1) sharing brokerage with ICICI Bank does not invalidate the expenditure, (2) the bank's deposit earnings cannot negate the assessee's legitimate business expense, and (3) the expenses were directly connected to the broking business infrastructure. Regarding notional losses, the court followed SC precedent in Suzlon Energy Ltd, allowing deductions based on conservative accounting principles. No substantial questions of law were identified, and both revenue's and assessee's proposed questions were consequently dismissed.
HC held that client assistant charges paid to ICICI Bank Ltd constitute legitimate business expenditure. The court rejected revenue's disallowance of expenses, finding that: (1) sharing brokerage with ICICI Bank does not invalidate the expenditure, (2) the bank's deposit earnings cannot negate the assessee's legitimate business expense, and (3) the expenses were directly connected to the broking business infrastructure. Regarding notional losses, the court followed SC precedent in Suzlon Energy Ltd, allowing deductions based on conservative accounting principles. No substantial questions of law were identified, and both revenue's and assessee's proposed questions were consequently dismissed.
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TaxTMI 
TaxTMI 
of 4918 
