Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
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Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT dismissed revenue's appeal regarding disallowance under section 36(1)(iii) for interest-free advances to sister concern. Assessee company provided interest-free loan to sister concern while claiming interest deduction on secured loans from banks and financial institutions. CIT(A) deleted additions after examining remand report, finding no evidence that advances were made for non-business purposes. CIT(A) noted investee company regularly paid advance tax with effective tax rate exceeding assessee's rate. ITAT upheld CIT(A)'s decision, concluding the issue was examined correctly and additions were rightly deleted, establishing commercial expediency justified the interest-free advances despite simultaneous borrowing costs.
ITAT dismissed revenue's appeal regarding disallowance under section 36(1)(iii) for interest-free advances to sister concern. Assessee company provided interest-free loan to sister concern while claiming interest deduction on secured loans from banks and financial institutions. CIT(A) deleted additions after examining remand report, finding no evidence that advances were made for non-business purposes. CIT(A) noted investee company regularly paid advance tax with effective tax rate exceeding assessee's rate. ITAT upheld CIT(A)'s decision, concluding the issue was examined correctly and additions were rightly deleted, establishing commercial expediency justified the interest-free advances despite simultaneous borrowing costs.
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TaxTMI 
TaxTMI 
of 4918 
