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...
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ITAT Decision Summary: The ITAT comprehensively allowed multiple tax-related claims for the assessee, including: (a) validating internal CUP benchmarking for interest on advances to associated enterprises, (b) rejecting notional interest adjustments on outstanding receivables, (c) permitting weighted deduction under section 35(2AB) for R&D expenditure, (d) upholding depreciation on goodwill from intra-group amalgamation, (e) deleting disallowances related to common expense allocation, (f) rejecting interest capitalization disallowance under section 36(1)(iii), (g) dismissing section 14A disallowance, and (h) upholding non-deduction of TDS on non-resident commission. The tribunal consistently followed precedential rulings and applied principles of commercial reality, predominantly deciding in favor of the assessee across multiple tax dispute grounds.
ITAT Decision Summary: The ITAT comprehensively allowed multiple tax-related claims for the assessee, including: (a) validating internal CUP benchmarking for interest on advances to associated enterprises, (b) rejecting notional interest adjustments on outstanding receivables, (c) permitting weighted deduction under section 35(2AB) for R&D expenditure, (d) upholding depreciation on goodwill from intra-group amalgamation, (e) deleting disallowances related to common expense allocation, (f) rejecting interest capitalization disallowance under section 36(1)(iii), (g) dismissing section 14A disallowance, and (h) upholding non-deduction of TDS on non-resident commission. The tribunal consistently followed precedential rulings and applied principles of commercial reality, predominantly deciding in favor of the assessee across multiple tax dispute grounds.
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