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 penalty case involving outward remittances to Chinese companies. The tribunal found that the assessee was under a bona fide belief regarding Form 15CA submission, as the relevant rules prescribing the form were not notified until 01.04.2016, despite section 195(6) amendment on 01.06.2015. The lower authorities' imposition of penalty under section 271(1)(c) was deemed unjustified, given the lack of clear regulatory guidance during the relevant period. The tribunal consequently ruled in favor of the assessee, effectively quashing the penalty proceedings.
ITAT adjudicated a tax penalty case involving outward remittances to Chinese companies. The tribunal found that the assessee was under a bona fide belief regarding Form 15CA submission, as the relevant rules prescribing the form were not notified until 01.04.2016, despite section 195(6) amendment on 01.06.2015. The lower authorities' imposition of penalty under section 271(1)(c) was deemed unjustified, given the lack of clear regulatory guidance during the relevant period. The tribunal consequently ruled in favor of the assessee, effectively quashing the penalty proceedings.
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TaxTMI 
TaxTMI 
of 4918 
