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...
ITAT rejected the assessee's claim for deducting interest on delayed deposit of employee provident fund contributions. The tribunal held that interest on late PF deposits cannot be claimed as a business expenditure under Section 37(1). The non-obstante clause of Section 43B mandates timely payment of statutory liabilities, and employee contributions are trust monies that must be deposited within specified due dates. Explanation 1 to Section 37 prohibits deductions for legally prohibited actions. The tribunal upheld the CPC's disallowance, emphasizing the legislative intent to protect workers' social security by ensuring timely remittance of statutory dues. Appeal was decided against the assessee.
ITAT rejected the assessee's claim for deducting interest on delayed deposit of employee provident fund contributions. The tribunal held that interest on late PF deposits cannot be claimed as a business expenditure under Section 37(1). The non-obstante clause of Section 43B mandates timely payment of statutory liabilities, and employee contributions are trust monies that must be deposited within specified due dates. Explanation 1 to Section 37 prohibits deductions for legally prohibited actions. The tribunal upheld the CPC's disallowance, emphasizing the legislative intent to protect workers' social security by ensuring timely remittance of statutory dues. Appeal was decided against the assessee.
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