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 ruled on multiple taxation issues for the assessee engaged in software development. The tribunal partially allowed the assessee's appeals, addressing key points: (1) computers used for software production qualify as plant and machinery eligible for additional depreciation under Section 32(1)(iia), (2) investment allowances under Section 32AC are permissible for computers used in software development, not administrative purposes, (3) suo-moto disallowance under Section 14A was accepted, (4) foreign tax deduction was allowed following precedent, and (5) MAT credit issue was remanded to Assessing Officer for fresh adjudication. The appeals were predominantly decided in favor of the assessee, with directions for detailed verification by the AO.
ITAT ruled on multiple taxation issues for the assessee engaged in software development. The tribunal partially allowed the assessee's appeals, addressing key points: (1) computers used for software production qualify as plant and machinery eligible for additional depreciation under Section 32(1)(iia), (2) investment allowances under Section 32AC are permissible for computers used in software development, not administrative purposes, (3) suo-moto disallowance under Section 14A was accepted, (4) foreign tax deduction was allowed following precedent, and (5) MAT credit issue was remanded to Assessing Officer for fresh adjudication. The appeals were predominantly decided in favor of the assessee, with directions for detailed verification by the AO.
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