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...
HC analyzed income accrual under mercantile accounting system, addressing electricity charge recoveries. The tribunal found that the assessee had correctly adjusted receivables from the state electricity board across multiple assessment years without double taxation. The tribunal determined that adding the disputed amount would constitute duplicate taxation, as the income was already recognized in subsequent years consistent with Supreme Court directives. Consequently, the tribunal granted relief to the assessee, concluding no substantial legal question existed in the appeal.
HC analyzed income accrual under mercantile accounting system, addressing electricity charge recoveries. The tribunal found that the assessee had correctly adjusted receivables from the state electricity board across multiple assessment years without double taxation. The tribunal determined that adding the disputed amount would constitute duplicate taxation, as the income was already recognized in subsequent years consistent with Supreme Court directives. Consequently, the tribunal granted relief to the assessee, concluding no substantial legal question existed in the appeal.
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TaxTMI 
TaxTMI 
of 4921 
