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 transfer pricing and tax-related issues. Key outcomes include: directing TPO to exclude certain comparables from transfer pricing analysis, allowing deduction of forex derivative mark-to-market losses, instructing AO to reexamine disallowances related to bad debts and business expenses, and confirming non-applicability of MAT provisions for banking institutions. The tribunal generally provided directives for reassessment, emphasizing compliance with legal precedents and granting opportunities for the assessee to substantiate claims. Most disputed items were remanded for fresh examination in accordance with established legal principles and Supreme Court interpretations.
ITAT ruled on multiple transfer pricing and tax-related issues. Key outcomes include: directing TPO to exclude certain comparables from transfer pricing analysis, allowing deduction of forex derivative mark-to-market losses, instructing AO to reexamine disallowances related to bad debts and business expenses, and confirming non-applicability of MAT provisions for banking institutions. The tribunal generally provided directives for reassessment, emphasizing compliance with legal precedents and granting opportunities for the assessee to substantiate claims. Most disputed items were remanded for fresh examination in accordance with established legal principles and Supreme Court interpretations.
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TaxTMI 
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