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 allowed the assessee's appeal, holding that the entire unsecured loan was utilized for business purposes with commercial expediency. The tribunal found no evidence of personal or capital usage of loan funds. The AO's disallowance of interest was deemed speculative, particularly when TDS was duly deducted. The tribunal concluded that the addition under Section 36(1)(iii) should be deleted, recognizing the loan's exclusive business application and the assessee's improved buying capacity leading to better gross profit margins.
ITAT allowed the assessee's appeal, holding that the entire unsecured loan was utilized for business purposes with commercial expediency. The tribunal found no evidence of personal or capital usage of loan funds. The AO's disallowance of interest was deemed speculative, particularly when TDS was duly deducted. The tribunal concluded that the addition under Section 36(1)(iii) should be deleted, recognizing the loan's exclusive business application and the assessee's improved buying capacity leading to better gross profit margins.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
