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...
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ITAT adjudicated a TDS dispute under sections 194IA and 195, finding the assessee failed to substantively demonstrate compliance with first proviso to section 201(1). Despite incomplete initial documentation, the tribunal exercised discretion by remanding the case, providing the assessee an additional opportunity to present comprehensive evidence before the Assessing Officer. The appellate order set aside the lower court's decision, restoring all demand-related issues for fresh examination, and technically allowed the assessee's appeal for statistical purposes, thereby preserving procedural fairness while maintaining statutory scrutiny of tax deduction requirements.
ITAT adjudicated a TDS dispute under sections 194IA and 195, finding the assessee failed to substantively demonstrate compliance with first proviso to section 201(1). Despite incomplete initial documentation, the tribunal exercised discretion by remanding the case, providing the assessee an additional opportunity to present comprehensive evidence before the Assessing Officer. The appellate order set aside the lower court's decision, restoring all demand-related issues for fresh examination, and technically allowed the assessee's appeal for statistical purposes, thereby preserving procedural fairness while maintaining statutory scrutiny of tax deduction requirements.
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