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 two key issues: (1) Disallowance of "Other Discounts" and (2) Addition under Section 45(4). In the first matter, the Tribunal reversed lower authorities' disallowance, finding the discount was a legitimate prompt payment discount substantiated by subsequent invoices and party-specific details. Regarding Section 45(4), the Tribunal held that introducing a new partner with fresh capital does not constitute asset transfer, thus Section 45(4) was inapplicable. Relying on judicial precedents, the Tribunal directed the Assessing Officer to delete the addition, ultimately deciding both grounds in favor of the assessee.
ITAT adjudicated two key issues: (1) Disallowance of "Other Discounts" and (2) Addition under Section 45(4). In the first matter, the Tribunal reversed lower authorities' disallowance, finding the discount was a legitimate prompt payment discount substantiated by subsequent invoices and party-specific details. Regarding Section 45(4), the Tribunal held that introducing a new partner with fresh capital does not constitute asset transfer, thus Section 45(4) was inapplicable. Relying on judicial precedents, the Tribunal directed the Assessing Officer to delete the addition, ultimately deciding both grounds in favor of the assessee.
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TaxTMI 
TaxTMI 
of 4918 
