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...
ITAT allowed partial relief to the assessee, directing deletion of multiple disallowances. The tribunal found no merit in the AO's disallowance of vehicle depreciation and interest expenses, citing possession and usage of assets as key determinants of ownership. Business promotion expenses appeal was dismissed due to cash expenditure. Loan interest disallowance was deleted citing insufficient nexus. The tribunal also set aside notional income addition on building construction expenditure and 5% salary expenses disallowance, emphasizing lack of substantive evidence and procedural irregularities in the AO's assessment. The ruling predominantly favored the assessee by directing removal of several disputed additions.
ITAT allowed partial relief to the assessee, directing deletion of multiple disallowances. The tribunal found no merit in the AO's disallowance of vehicle depreciation and interest expenses, citing possession and usage of assets as key determinants of ownership. Business promotion expenses appeal was dismissed due to cash expenditure. Loan interest disallowance was deleted citing insufficient nexus. The tribunal also set aside notional income addition on building construction expenditure and 5% salary expenses disallowance, emphasizing lack of substantive evidence and procedural irregularities in the AO's assessment. The ruling predominantly favored the assessee by directing removal of several disputed additions.
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