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 the assessee's appeals, rejecting the claim that the transfer of assets through a restructuring scheme constituted a demerger under section 2(19AA). The tribunal found the transaction was a specific asset transfer to liquidate debts, not meeting demerger criteria. The assets were transferred at fair market value, with the land sold at Rs. 65 crores against an indexed cost of Rs. 68.32 crores, and shares transferred to settle liabilities. The tribunal upheld the assessee's method of recording transactions, deleted disallowances related to notional interest on inter-group loans, section 14A provisions, and staff welfare expenses, essentially ruling in favor of the assessee's computational approach and commercial rationale.
ITAT allowed the assessee's appeals, rejecting the claim that the transfer of assets through a restructuring scheme constituted a demerger under section 2(19AA). The tribunal found the transaction was a specific asset transfer to liquidate debts, not meeting demerger criteria. The assets were transferred at fair market value, with the land sold at Rs. 65 crores against an indexed cost of Rs. 68.32 crores, and shares transferred to settle liabilities. The tribunal upheld the assessee's method of recording transactions, deleted disallowances related to notional interest on inter-group loans, section 14A provisions, and staff welfare expenses, essentially ruling in favor of the assessee's computational approach and commercial rationale.
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