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 held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
ITAT held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
