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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The ITAT addressed multiple taxation issues for the assessee. The tribunal partially allowed deductions under Section 80-IA against gross total income, not restricting it to business income, following Supreme Court precedent in Reliance Energy Limited. Club expenses were allowed based on consistent historical treatment. CSR donation deductions under Section 80G were upheld. The tribunal restored the weighted deduction claim under Section 35(2)(ab) to the AO for fresh consideration, providing an opportunity to submit Form 3CL. Disallowance under Section 14A was dismissed, and transfer pricing adjustments related to power transfer were evaluated based on arm's length pricing methodologies established in prior judicial interpretations.
The ITAT addressed multiple taxation issues for the assessee. The tribunal partially allowed deductions under Section 80-IA against gross total income, not restricting it to business income, following Supreme Court precedent in Reliance Energy Limited. Club expenses were allowed based on consistent historical treatment. CSR donation deductions under Section 80G were upheld. The tribunal restored the weighted deduction claim under Section 35(2)(ab) to the AO for fresh consideration, providing an opportunity to submit Form 3CL. Disallowance under Section 14A was dismissed, and transfer pricing adjustments related to power transfer were evaluated based on arm's length pricing methodologies established in prior judicial interpretations.
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