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 partially allowed assessee's appeal regarding transfer pricing (TP) adjustment for corporate guarantee. The Tribunal held the corporate guarantee as an international transaction and directed the TPO/AO to compute the guarantee fee at 0.5% rate, deleting excess amount added. Regarding interest under section 244A, the Tribunal directed the assessee to approach the AO, who shall consider the interest claim in accordance with law, with the Principal Commissioner having final decision-making authority on interest period and calculation.
ITAT partially allowed assessee's appeal regarding transfer pricing (TP) adjustment for corporate guarantee. The Tribunal held the corporate guarantee as an international transaction and directed the TPO/AO to compute the guarantee fee at 0.5% rate, deleting excess amount added. Regarding interest under section 244A, the Tribunal directed the assessee to approach the AO, who shall consider the interest claim in accordance with law, with the Principal Commissioner having final decision-making authority on interest period and calculation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
