Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
ITAT partially allowed assessee's appeal, affirming arm's-length royalty payments and consultancy service expenses based on consistent prior year rulings. The tribunal directed deletion of transfer pricing adjustments related to expatriate costs and reimbursements. Regarding income tax liability provision, the tribunal accepted the assessee's contention that reversal of previously disallowed provision should not result in double taxation, allowing the ground subject to AO's verification. The decision upholds procedural fairness and prevents duplicative tax treatment of contingent liabilities.
ITAT partially allowed assessee's appeal, affirming arm's-length royalty payments and consultancy service expenses based on consistent prior year rulings. The tribunal directed deletion of transfer pricing adjustments related to expatriate costs and reimbursements. Regarding income tax liability provision, the tribunal accepted the assessee's contention that reversal of previously disallowed provision should not result in double taxation, allowing the ground subject to AO's verification. The decision upholds procedural fairness and prevents duplicative tax treatment of contingent liabilities.
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TaxTMI 
TaxTMI 
of 4915 
