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 dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
ITAT dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
