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 upheld CIT(A)'s decision allowing NHAI grant treatment as shareholder funds rather than asset cost reduction under section 43 Explanation (10) of I.T. Act, 1961. The grant constituted cash support for project viability and financial strength, not direct/indirect asset cost contribution, thus depreciation disallowance was inappropriate. However, ITAT reversed CIT(A) regarding periodic maintenance provisions, holding that under mercantile accounting, five-year accumulated maintenance expenses must be proportionately charged annually rather than entirely in the fifth year when repairs occur. The assessee's cross-appeal was dismissed as time-barred due to unexplained 1271-day delay, with ITAT finding insufficient reasonable cause despite assessee's participation in revenue's cross-appeal proceedings.
ITAT upheld CIT(A)'s decision allowing NHAI grant treatment as shareholder funds rather than asset cost reduction under section 43 Explanation (10) of I.T. Act, 1961. The grant constituted cash support for project viability and financial strength, not direct/indirect asset cost contribution, thus depreciation disallowance was inappropriate. However, ITAT reversed CIT(A) regarding periodic maintenance provisions, holding that under mercantile accounting, five-year accumulated maintenance expenses must be proportionately charged annually rather than entirely in the fifth year when repairs occur. The assessee's cross-appeal was dismissed as time-barred due to unexplained 1271-day delay, with ITAT finding insufficient reasonable cause despite assessee's participation in revenue's cross-appeal proceedings.
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