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 Decision Summary: The ITAT predominantly ruled against the assessee, dismissing most appeal grounds related to foreign exchange forward contracts, treating the transaction as a revenue receipt rather than capital in nature. The tribunal directed restoration of certain issues to CIT(A) for de novo adjudication, specifically regarding finance costs, notional gains on derecognition of financial liabilities, and closing stock matters. The tribunal confirmed the lower authorities' order on liquidated damages and section 14A provisions. Key findings emphasized the importance of full factual disclosure and compliance with statutory notices, with a clear warning that non-compliance could result in adverse interpretations against the assessee.
ITAT Decision Summary: The ITAT predominantly ruled against the assessee, dismissing most appeal grounds related to foreign exchange forward contracts, treating the transaction as a revenue receipt rather than capital in nature. The tribunal directed restoration of certain issues to CIT(A) for de novo adjudication, specifically regarding finance costs, notional gains on derecognition of financial liabilities, and closing stock matters. The tribunal confirmed the lower authorities' order on liquidated damages and section 14A provisions. Key findings emphasized the importance of full factual disclosure and compliance with statutory notices, with a clear warning that non-compliance could result in adverse interpretations against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
