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 adjudicated a tax dispute regarding depreciation claim on intangible assets. The tribunal held that the assessee's depreciation claim on intangible assets under development was legally sustainable. The court emphasized that not every revenue loss constitutes prejudice to revenue interests. Citing SC precedents, the tribunal confirmed that when an AO adopts a permissible approach and takes a reasonable view, the assessment cannot be considered erroneous. The tribunal quashed the CIT's order under Section 263, ruling that the depreciation claim on goodwill was allowable and did not cause revenue prejudice. Consequently, the assessee's appeal grounds were fully allowed, maintaining the original depreciation claim.
ITAT adjudicated a tax dispute regarding depreciation claim on intangible assets. The tribunal held that the assessee's depreciation claim on intangible assets under development was legally sustainable. The court emphasized that not every revenue loss constitutes prejudice to revenue interests. Citing SC precedents, the tribunal confirmed that when an AO adopts a permissible approach and takes a reasonable view, the assessment cannot be considered erroneous. The tribunal quashed the CIT's order under Section 263, ruling that the depreciation claim on goodwill was allowable and did not cause revenue prejudice. Consequently, the assessee's appeal grounds were fully allowed, maintaining the original depreciation claim.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
